BERENGRAVE NURSERY, RAINHAM. Planning Statement. Submitted on behalf of Gleeson Strategic Land

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1 BERENGRAVE NURSERY, RAINHAM Planning Statement Submitted on behalf of Gleeson Strategic Land October 2017

2 BERENGRAVE NURSERY, RAINHAM PLANNING STATEMENT SUBMITTED ON BEHALF OF GLEESON STRATEGIC LAND October 2017 Project Ref: 27239/A5 Status: Final Issue/Rev: 01 Date: October 2017 Prepared by: JM Checked by: AW Authorised by: AW Barton Willmore LLP The Observatory Southfleet Road Ebbsfleet Dartford Kent DA10 0DF Tel: Ref: 27239/A5/JM/ja Date: 24 October 2017 COPYRIGHT The contents of this document must not be copied or reproduced in whole or in part without the written consent of the Barton Willmore LLP. All Barton Willmore stationery is produced using recycled or FSC paper and vegetable oil based inks.

3 CONTENTS PAGE NO. 1.0 INTRODUCTION 01 i) Preparation and Submission of Supporting Documents 01 ii) Scope and Purpose of the Planning Statement SITE LOCATION AND DESCRIPTION 04 i) The Site 04 ii) Surrounding Area 05 iii) Planning History PROPOSED DEVELOPMENT 08 i) Residential Development 08 ii) Access and Parking 09 iii) Design Principles 10 iv) Informed Proposals PLANNING POLICY CONTEXT 13 i) Introduction 13 ii) National Planning Policy Framework (2012) 14 iii) Planning Practice Guidance (2014) 21 iv) The Development Plan 23 v) Emerging Medway Local Plan vi) Development Plan/Housing Land Supply 31 vii) Strategic Housing & Economic Needs Assessment (SHENA) (March 2015) 31 viii) Strategic Land Availability Assessment (SLAA) (January 2017) PLANNING ANALYSIS 33 i) Principle of Sustainable Development 34 ii) Residential Development 37 iii) Definition of Sustainable Development 39 iv) Design and Layout 42 v) Open Space 43 vi) Transport and Traffic 43 vii) Flooding and Drainage 45 viii) Landscape and Visual 46 ix) Ecology 48 x) Arboriculture 51 xi) Agricultural Land Classification 52 xii) Archaeology 53 xiii) Noise 54 xiv) Air Quality 54 xv) Contamination 55

4 xvi) Section 106 Heads of Terms PLANNING BALANCE/CONCLUSIONS 57

5 APPENDICES Appendix A: Site Location Plan (Drawing ) Appendix B: Medway Council EIA Screening Opinion (MC/17/3223) (3 October 2017) Appendix C: Medway Council Pre-Application Advice Letter (PRE/17/2112) (4 October 2017) Appendix D: Economic Benefits Statement Appendix E: Medway Council SLAA Assessment (Berengrave Nursery Site 817)

6 Introduction 1.0 INTRODUCTION 1.1 This Planning Statement has been prepared on behalf of Gleeson Strategic Land Ltd (the Applicant) in support of an Outline planning application submitted in respect of Berengrave Nursery, Berengrave Lane, Rainham (hereafter referred to as the Site ) as shown on the Site Boundary Plan (Appendix A). The Site is located within the administrative area of Medway Council (MC). 1.2 The application description is as follows: Outline Planning Application (with all matters reserved except for means of access) for demolition of existing structures and erection of up to 121 residential dwellings including new vehicle access, internal roads, car parking, open spaces, sustainable urban drainage systems, earthworks and associated landscaping and infrastructure. 1.3 Outline approval is sought, together with the means of access. All other matters are reserved. i) Preparation and Submission of Supporting Documents 1.4 In order to prepare a comprehensive and thorough assessment to support the planning application, a number of specialist technical advisors and consultants have been appointed by the Applicant. 1.5 In addition to this Planning Statement, the following documents/technical reports have been prepared to accompany the application (Table 1): 27239/A5/JM/ja 1 October 2017

7 Introduction Table 1: Planning Application Reports Report Design and Access Statement Statement of Community Involvement Economic Benefits Statement (appended to this planning statement at Appendix D) Preliminary Ecological Appraisal Bird Survey Report 2017 Reptile Survey 2017 Bat Activity Survey 2017 Dormouse Survey 2017 Badger Survey Letter (19 th October 2017) Landscape and Visual Appraisal Flood Risk Assessment Foul and Surface Water Drainage Assessment Agricultural Land Classification Report Archaeological Desk-based Assessment Phase 1 Geo-Environmental Desk Study Report Transport Assessment Environmental Noise Impact Assessment Arboricultural Development Report Air Quality Assessment Consultant Richards Urban Design Ltd Barton Willmore Barton Willmore The Ecology Partnership The Ecology Partnership The Ecology Partnership The Ecology Partnership The Ecology Partnership The Ecology Partnership Environmental Dimension Partnership Ltd Weetwood Weetwood RSK ADAS Ltd Thames Valley Archaeological Services BRD Environmental Limited i-transport Sound Advice Acoustics tree:fabric Phlorum 1.6 The following plans and drawings have been submitted for determination: Site Location Plan (Drawing ) Land Use Parameter Plan (Drawing ) Proposed Site Access Plan (Drawing ITB12519-GA-001 Revision C) 1.7 The application is supported by the following illustrative material, demonstrating that the Site can be developed for the amount of development proposed within the outline application: Illustrative Site Layout Plan (Drawing ) 1.8 Medway Council adopted a Screening Opinion (Ref: MC/17/3223) dated 3 October 2017 that the proposed development is not EIA development. A copy of the decision notice is attached at Appendix B /A5/JM/ja 2 October 2017

8 Introduction ii) Scope and Purpose of the Planning Statement 1.9 The purpose of this Planning Statement is to assess the planning merits of the application, explain the form and content of the application proposals against adopted and emerging policy guidance and best practice, and to assess the proposals in the light of any other material considerations The proposed development needs to be assessed in the context of the Development Plan and other material considerations. This statement carries out the that assessment and seeks to address the implications of the development on the surrounding area and justifies the submission of the Outline planning application The Planning Statement therefore: Describes the Site and the surrounding area (Section 2); Describes the proposed Development (Section 3); Identifies the Planning Policy Framework by reviewing the relevant National and Local planning policy and guidance (Section 4); Provides a Planning Analysis of the proposed development against the key material considerations (Section 5); Undertakes a Planning Balancing exercise/provides conclusions on the material considerations which should be taken into account in the determination of the planning application (Section 6) It is the conclusion of the Planning Statement that the proposals accord with National planning policy guidance and represent a sustainable form of development that would deliver much needed market and affordable housing and should be supported by the Council and approved without unnecessary delay /A5/JM/ja 3 October 2017

9 Site Location and Description 2.0 SITE LOCATION AND DESCRIPTION i) The Site 2.1 The Site is irregular in shape and totals approximately 5.83 hectares, located to the south east of Lower Bloors Lane and to the west of Berengrave Lane. Berengrave Lane runs on a broadly north/south alignment between Lower Rainham Road (B2004) to the north and London Road (A2) to the south. 2.2 The Chatham Main railway line runs forms the south-western boundary of the Site. Bloors Lane Community Woodland, an area of woodland owned and maintained by Medway Council, is located adjacent to the north-western Site boundary. A Public Right of Way (PROW) (GB5) runs along the northwest boundary of the Site, providing a pedestrian link between Berengrave Lane and Lower Rainham Road. The further PROW (GB6) runs through the Site connecting footpath GB5 (at its eastern end) with Bloors Lane at its western end. 2.3 The Site consists of an active retail garden nursery, including: Open car parking area at the southern end of the Site; A number of retail display areas at the front of the Site (including associated buildings and structures); Plant growing areas within the Site including meshed tunnel structures; Open storage areas within the Site together with a number of associated buildings; Areas of scrub and planting within the northern part of the Site; A grassed area which has been cleared for use as an archery range; and A number of young trees/shrubs that have self-planted. 2.4 These elements collectively including horticultural and commercial uses largely associated with the active retail garden nursery. The Site contains a variety of other built structures and hard standings. 2.5 The Site is accessed via an existing vehicular entrance on the western side of Berengrave Lane. Land levels within the Site range between approximately 16.9m AOD and 27.3m AOD with a general fall in levels from the south west to the north east, with an area of higher ground running through the centre of the Site. 2.6 The Site is located entirely within Flood Zone /A5/JM/ja 4 October 2017

10 Site Location and Description ii) Surrounding Area 2.7 The town of Rainham forms part of the Medway Towns conurbation in the county of Kent. The eastern and southern boundaries of the Site follow the existing settlement boundary of Rainham. The Site is currently outside but immediately adjacent to the Rainham settlement, and is in close proximity to existing residential, employment, retail and community developments. 2.8 To the south of the Site, Berengrave Lane passes under a railway tunnel which is subject to one-way traffic signal shuttle control. 2.9 To the south of the Site (100m), beyond the railway line, is Rainham Cricket Ground which is the grounds for the well-established Rainham Cricket Club. Thames View Primary School is located approximately 980 metres to the west of the Site There is a detached residential bungalow directly to the north east of the Site boundary. Further north of this bungalow, there is a group of storage buildings and a telecommunications mast. The bungalow, storage buildings and telecommunications mast are currently accessed via a driveway which runs along the edge of the Site The wider area is generally characterised by detached and semi-detached dwellings which flank the northern and southern sides of Berengrave Lane, together with residential properties within Holmoaks to the south of the Site, beyond the mainline railway line The town centre of Rainham is located approximately 1.05 km to the south of the Site, and provides a range of services and facilities including shops, a supermarket, GP Practice/medical centre, hotel and library Rainham Railway Station is located approximately 1.05 km from the centre of the Site, which provides approximately 2-3 trains per hour to London (Victoria and St Pancras Stations) in approximately 1 hour s travel. Other destinations from Rainham Railway Station include Gillingham (5 minutes journey time), Sittingbourne (8 minutes journey time), Faversham (20 minutes journey time), Ramsgate (1-hour journey time) and Dover Priory (50 minutes journey time) /A5/JM/ja 5 October 2017

11 Site Location and Description 2.14 Nearby bus stops to the Site are located on Childscroft Road, approximately 250m to the east of the centre of the Site. Additional bus stops are accessible from the Site and are located approximately 360m north on Berengrave Lane and 860m on London Road (A2). Bus services from these stops provide links to Maidstone, Hempstead Valley, Medway Maritime Hospital, Chatham, Gillingham and Sittingbourne National Cycle Route 1, which extends across the east coast of England, runs through the town close to the site along Berengrave Lane and Childscroft Road The M2 motorway runs along the southern edge of Rainham, two miles (6km) from the town centre. The main road through the town centre, the A2, follows the ancient Watling Street, the Roman road between London and Canterbury. The most northerly road, Lower Rainham Road, runs close to the southern bank of the river Berengrave Local Nature Reserve, a designated Country Park, lies some 300m north-east of the Site. The nearest park (including children s play area) is at Cozenton Park, some 450m to the south of the Site. The Site is within 2km of the Medway Estuary and Marshes Site of Special Scientific Interest (SSSI), Special Protection Area (SPA) and Ramsar site. iii) Planning History 2.18 There has been a number of historic planning applications on the Site as outlined below (see Table 2). Table 2: Historic Planning Applications Ref Development Description Decision MC/17/3223 Town and Country Planning Act (EIA) Regulations 2017 Request for a screening opinion for an outline application for the construction of up to 140 residential dwellings with associated infrastructure, groundworks, demolition, open space and landscaping with all matters reserved except for access TEMP/06/2152 Change of use from agricultural packing shed into an office EIA not required Withdrawn 27239/A5/JM/ja 6 October 2017

12 Site Location and Description MC/06/1106 Siting of 2 containers to be used as store and rest room and extension to scaffold yard area MC/06/0234 Erection of 2 containers to be used as a store and as a rest room MC/05/2471 Proposed increase in height of telecommunications mast by 3 metres and re-location of antennae MC/05/1628 Use of the land for the storage of scaffolding. The hours of operation are Monday to Friday 0700 to 1700; Saturday 0700 to In terms of scaffold lorries there are no more than 6 inbound and 6 outbound trips per day Monday to Friday. On Saturday s there are no more than 3 inbound and 3 outbound scaffold lorry trips HIS/98/72548 Application for the prior approval under Part 24 of the Town and Country Planning (General Permitted Development) Order 1995 for the erection of a 15m radio tower and equipment cabin. Refused 5 October 2006 Appeal Dismissed August 2007 Withdrawn Approved February 2006 Certificate of Existing Lawful Use issued October 2005 Application not required /A5/JM/ja 7 October 2017

13 Proposed Development 3.0 PROPOSED DEVELOPMENT 3.1 As outlined above, the application description is as follows: Outline Planning Application (with all matters reserved except for means of access) for demolition of existing structures and erection of up to 121 residential dwellings including new vehicle access, internal roads, car parking, open spaces, sustainable urban drainage systems, earthworks and associated landscaping and infrastructure. 3.2 The application is submitted in Outline form, with all matters reserved except access. A Land Use Parameter Plan (Drawing No ) is submitted for approval. An Illustrative Site Layout Plan (Drawing No ) has been submitted as an illustrative layout plan of how the Site could be developed at the subsequent detailed Reserved Matters stage. i) Residential Development 3.3 The proposed development provides for up to 121 residential dwellings located within Medway Council. The building heights will predominantly be storeys for terraced and detached/semi-detached dwellings, and 3 storeys for apartment buildings. 3.4 The proposed residential dwellings will be situated within an area of land of approximately 3.6ha. The remainder of the Site, circa 2.2ha of land, will be laid out with open space, landscape planting and associated infrastructure including Sustainable Urban Drainage Systems (SUDS). The overall gross density across the Site is 21 dwellings per hectare (dph), with a net density of 34 dph. 3.5 It is proposed that the development will accommodate a mix of dwelling types and sizes, with up to 25% affordable dwellings. The specific housing mix is not fixed at this stage due to the Outline nature of the application. The final mix will respond to design and market considerations at any subsequent Reserved Matters stage. The indicative housing mix is as follows: Table 3: Indicative Housing Mix Market Affordable Total 1-bed flat 0 (0%) 12 (40%) 12 2-bed flat 0 (0%) 12 (40%) 12 2-bed house 15 (16%) bed house 45 (50%) 5 (17%) /A5/JM/ja 8 October 2017

14 Proposed Development 4-bed house 31 (34%) 1 (3%) 32 Total 90 (100%) 30 (100%) 121 ii) Access and Parking 3.6 A new primary vehicular access is proposed from Berengrave Lane situated to the south of the Site. The proposed new vehicular access comprises a simple priority T junction on Berengrave Lane in the vicinity of the existing site access to Berengrave Nursery. It will comprise a 5.5m wide carriageway width with 2m wider footways to either side to tie in with the existing footway on Berengrave Lane. Visibility from the new site access junction will be provided commensurate with the 30mph speed limit on Berengrave Lane in the vicinity of the site access. 3.7 Separate from the proposed new access, the existing access is to remain to serve the adjoining bungalow, storage buildings and telecommunications mast only on the eastern boundary. Any alternative access arrangements to these properties could be addressed at the Reserved Matters stage if necessary. 3.8 Pedestrian and cycle access points are proposed as part of the development, including linkage from within the Site to the adjoining public footpath on the north-eastern site boundary, linkage into the Site from Berengrave Lane either sides of the new vehicular access. There is potential for future pedestrian link from the Site into the adjacent Bloors Lane Community Woodland to the south west. 3.9 Detailed discussions have been held with Medway Council as the Local Highway Authority, and Highways England as the Strategic Highway Authority, prior to the submission of the planning application. A thorough assessment of existing and proposed transport movements, including vehicular, pedestrian and public transport facilities is contained in the Transport Assessment As the overall mix of housing units is not fixed at this outline stage, there are no fixed proposals in respect of parking provision. However, it is proposed that the development will fully comply with current adopted policy in respect of both car and cycle parking provisions. Principles for parking provision are contained in the submitted Transport Assessment, which includes welldesigned on-street visitor parking and dedicated lay-bys /A5/JM/ja 9 October 2017

15 Proposed Development iii) Design Principles 3.11 Overall, the development form has been derived from an attention to conserving the local landscape character and features of the Site, as clearly explained within the Design and Access Statement (Richards Urban Design) Whilst detailed matters of Layout, Appearance, Landscaping are reserved matters for future consideration, an Illustrative Site Layout Plan (Drawing ) has been submitted to demonstrate that the Site has capacity to accommodate the quantum of development proposed Within the Illustrative Site Layout Plan, and further explained in the accompanying Design and Access Statement, the layout of individual dwellings, open spaces, landscape buffers and a street hierarchy are indicatively shown In addition, the application is accompanied by a Landscape and Visual Appraisal (Environmental Dimension Partnership Ltd) which has informed the emerging masterplan proposals from an early stage in the design process. Specifically, the appraisal work has aimed to: Integrate the proposed development with the landscape and the existing settlement pattern so as to minimise adverse landscape and visual effects, taking into consideration the Area of Local Landscape Importance (ALLI) designation; Provide an attractive setting to the proposed development based upon the surrounding landscape character; Retain existing trees and shrubs within the site perimeters; Provision of a local children s play area; Integrate the surrounding Public Rights of Way into the proposed development, and a potential future link to Bloors Lane Community Woodland; and Incorporate SUDS measures as an integral part of the scheme The Design and Access Statement accompanying this application explains the design concept of the proposal in further detail In conclusion, a collaborative design approach has been adopted to ensure the delivery of a comprehensive high-quality development which responds to the character and setting of the Site and its surroundings /A5/JM/ja 10 October 2017

16 Proposed Development iv) Informed Proposals 3.17 The Outline planning application has been informed by engagement with the local community through a Public Consultation Leaflet distributed in August 2017, together with formal preapplication discussions with MC officers. A pre-application meeting with MC officers took place on 30 August 2017 which was followed up by written feedback on 4 October 2017 (Appendix C). A summary of the pre-application response from MC is set out below: The Council recognise that it does not have a 5-year housing land supply. As a result of the shortfall in the housing land supply, paragraphs 14 and 49 of the NPPF apply, and relevant policies for the supply of housing should be considered not up-to-date; The Site does for fall within any designations outlined within Footnote 9 of the NPPF (i.e. it is not within a site protected under the Birds and Habitats Directive, SSSI, Green Belt, Local Green Space, AONB, Heritage Coast, within a National Park, a designated heritage asset or areas at risk of flooding or coastal erosion); The urban boundaries as defined in the proposals map for the 2003 Medway Local Plan fall away, as does the weight carried by Local Plan Policy BNE25 relating to development in the countryside, and as such, the sustainability of the Site needs to be assessed in line with the definition of sustainable development as outlined in the NPPF; The Site was assessed in the Medway Council Strategic Land Availability Assessment, January 2017 (Site Ref: 817) as being suitable and available for residential development with an overall capacity of 151 units; 3.18 Furthermore, the Council s pre-application advice letter (Appendix C) indicates that the key planning considerations relevant to the proposed development can be summarised into the following main themes: Sustainability of the proposals in terms of economic, social and environmental considerations; Landscape impacts in the context of the Area of Local Landscape Importance (ALLI) designation; Proposed housing mix and affordable housing provisions; Permeability of the site and opportunities for improved pedestrian access to the adjoining Bloors Lane Community Woodland and surrounding public footpath network; Highway impacts; Surface water and drainage impacts including the provision of a Sustainable Urban Drainage System; Loss of agricultural land; 27239/A5/JM/ja 11 October 2017

17 Proposed Development Land contamination taking into account the previous/historic uses of the Site; Ecological impacts including ecological potential within the site and in respect of a contribution towards the protection of birds in the North Kent Marshes SPA/Ramsar sites; Tree impacts; Archaeological impacts; and Noise impacts taking into consideration the proximity of the Site to the adjoining Railway line During the preparation of the application, discussions have taken place with various Council officers to ascertain site drainage requirements, and agree the scope/methodology for the submitted noise, air quality and transport assessments In addition to the formal pre-application engagement with MC officers, a presentation of the proposals will be provided to Members of Medway Council on 30 October This had originally been arranged for 19 September 2017, but had to be rescheduled due to political party conferences These meetings and public engagement have informed the evolution of the residential scheme proposals, resulting in an Outline application that has been influenced and shaped by local stakeholders, wherever possible Further information on the pre-application consultation process is set out in the accompanying Statement of Community Involvement (Barton Willmore, October 2017), submitted in support of this Outline planning application A formal Planning Performance Agreement between the Applicant and Medway Council has been prepared and entered into to demonstrate a proactive approach to the determination of the planning application /A5/JM/ja 12 October 2017

18 Planning Policy Context 4.0 PLANNING POLICY CONTEXT i) Introduction 4.1 The following section of this report identifies the most relevant planning policy and guidance at the National and Local levels. Only policies relevant to the consideration of this application are included. The proposals are assessed against the relevant policy and guidance on a topic basis in the following section. 4.2 Section 38(6) of the Planning and Compulsory Purchase Act (2004) states that the determination of planning applications must be made in accordance with the Development Plan unless material considerations indicate otherwise. 4.3 The Development Plan for the Site comprises the following: Medway Council Local Plan (2003) Saved Policies. 4.4 Other material considerations relevant to this application include the following documents: National Planning Policy Framework (2012); National Planning Practice Guidance; Air Quality Guidance (Medway Council, April 2016); and Medway Landscape Character Assessment (2011). 4.5 MC is in the process of preparing a new Local Plan ( ) which will replace the 2003 Medway Local Plan. The first stage Issues and Options consultation was held between January and February A second stage Development Options consultation was undertaken between January and May This recognises that MC will seek to provide a supply of land to meet the needs for market and affordable housing for 29,463 homes over the plan period. 4.6 To support the preparation of the new Local Plan, MC has published a Strategic Land Availability Assessment (SLAA) in January 2017 focussing on the potential for residential development within its administrative area. A total of 53 sites were deemed to be suitable, available and achievable for residential development amounting to a potential for 5,980 new residential units across Medway. The application Site, referred to as Site 817: Berengrave Nursery, Rainham is identified within the published MC 2017 SLAA as Suitable and Available for residential development with a capacity of 151 units /A5/JM/ja 13 October 2017

19 Planning Policy Context 4.7 Importantly, Medway Council has acknowledged within its pre-application advice (Appendix C) that it cannot demonstrate a 5-year housing land supply. The Council s current housing land supply currently stands at within the range of years (based on appeal decision for Land at Gibraltar Farm, Hempsted dated 6 March 2017 as discussed further below). On this basis, the NPPF paragraph 49 is a material consideration. ii) National Planning Policy Framework The NPPF sets out the Government s planning policies for England and how these are expected to be applied and is a material consideration in all planning decisions. 4.9 The most significant aspect of the NPPF is the delivery and facilitation of sustainable development through the planning process. The NPPF (Para 14) puts at the forefront of planning generally a strong presumption in favour of sustainable development, which should be seen as a golden thread running through decision making, and aims to significantly increase the supply of housing Paragraph 7 of the NPPF identifies that there are three dimensions to sustainable development: economic, social and environmental. It is recognised that these roles should not be undertaken in isolation, because they are mutually dependent. Economic growth can secure higher social and environmental standards, and well-designed buildings and places can improve the lives of people and communities. Therefore, to achieve sustainable development, economic, social and environmental gains should be sought jointly and simultaneously through the planning system. (Para 8) Paragraph 14 of the NPPF states that where the Development Plan is absent, silent or relevant policies are out of date, LPAs should grant planning permission unless: Any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole; or Specific policies in the NPPF indicate development should be restricted In order to deliver sustainable development, the NPPF identifies 13No. themes against which schemes should be assessed, the relevant aspects of which are highlighted below /A5/JM/ja 14 October 2017

20 Planning Policy Context Delivering Sustainable Development Theme 1: Building a strong, competitive economy (Paras ) 4.13 One of the key objectives of the NPPF is to secure economic growth. Paragraph 19 states the Government is committed to ensuring that the planning system does everything it can to support sustainable economic growth. It continues Significant weight should be placed on the need to support economic growth. Theme 4: Promoting sustainable transport (Paras ) 4.14 Paragraph 30 encourages development that reduces the need to travel and supports sustainable transport modes. However, Para. 29 recognises that different policies and measures will be required in different communities and opportunities to maximise sustainable transport solutions will vary from urban to rural areas Paragraph 32 identifies that developments that generate significant amounts of movement should be supported by a transport assessment and ensure: Opportunities for sustainable transport modes have been taken up; Safe and suitable access can be achieved for all people; Improvements can be undertaken within the transport network that cost effectively limits the significant impacts; and that Development should only be prevented or refused where the residual cumulative impacts of development are severe Paragraph 35 seeks to ensure road layouts are well designed to cater for: Priority to pedestrians and cycle movements and access to public transport; Safe and secure layouts avoiding street clutter and home zones; and Consider the needs of people with disability The proposed development promotes sustainable transport modes and is considered to fully accord with this objective. Further information is set out in the accompanying Transport Assessment and Travel Plan, a summary of which is set out in Section 6 of this statement /A5/JM/ja 15 October 2017

21 Planning Policy Context 4.18 When determining local parking requirements for residential developments, Para. 39 sets out that LPAs should take into account the accessibility, type, mix and use of a development, availability of public transport, local car ownership levels and overall need to reduce vehicle emissions. Theme 6: Delivering a wide choice of high quality homes (Paras ) 4.19 Paragraph 47 expressly sets out that LPA s should boost significantly the supply of housing to deliver a wide choice of high quality homes that meet the demands and needs of a particular location by: meeting their full, objectively assessed needs (OAN) for housing, as far as is consistent with the other NPPF policies; and, identifying a supply of specific deliverable sites sufficient to provide 5-years worth of housing against their housing requirements with an additional buffer of 5% to ensure choice and competition (or 20% where there is a record of persistent under delivery) The proposed development will contribute to the supply of housing in the Borough and would help reduce the existing identified shortfall in 5-year housing supply. The development therefore fully accords with this objective Paragraph 49 of the NPPF states: Housing applications should be considered in the context of the presumption in favour of sustainable development. Relevant policies for the supply of housing should not be considered up-todate if the local planning authority cannot demonstrate a five-year supply of deliverable housing sites Section 5 of this Statement shows that the LPA cannot demonstrate a 5-year supply of housing. In this instance, the application for residential development should be considered in the context of the presumption in favour of sustainable development (Para. 14) Paragraph 50 expects the delivery of a wide choice of high quality homes and the creation of sustainable, inclusive and mixed communities. It goes on to identify that planning authorities should plan for a mix of housing based on current and future demographic trends, market trends and the needs of different groups in the community /A5/JM/ja 16 October 2017

22 Planning Policy Context Theme 7: Requiring Good Design (Paras ) 4.24 The NPPF attaches great importance to good design which is considered synonymous with sustainable development. Planning policies and decisions should therefore aim to ensure that developments: Function well and add to the quality of an area; Establish a strong sense of place; Optimise the potential of a Site; Respond to local character and history; Create a safe and accessible environment; and Be visually attractive and include appropriate landscaping However, paragraph 60 clearly establishes that planning policies and decisions should not attempt to impose architectural styles or particular tastes. This scheme is considered to positively respond to the above requirements This Outline Planning Application does not seek to secure permission for Layout, Appearance, Landscaping or Scale of the residential development, however the parameters for the development, along with the Design and Access Statement (DAS) show that the Development will accord with the NPPF paragraph 58 requirements. Theme 8: Promoting healthy communities (Paras ) 4.27 The NPPF identifies the role planning has in facilitating social interaction and creating healthy, inclusive communities. To achieve this, Para 69 seeks developments that promote: Safe and accessible environments where crime and disorder, and the fear of crime, do not undermine quality of life or community cohesion; and Safe and accessible developments, containing clear and legible pedestrian routes, and high quality public space, which encourage the active and continual use of public areas Paragraph 70 requires the provision of shared space, community facilities and other local services to enhance the sustainability of communities and residential environments. It also seeks to ensure an integrated approach to considering the location of housing, economic uses and community facilities and services. The Site is considered to successfully achieve these objectives /A5/JM/ja 17 October 2017

23 Planning Policy Context 4.29 Paragraph 72 seeks to ensure that sufficient choice of school places is available to meet the needs of existing and new communities. Developments are also required (Para. 73) to ensure access to high quality open spaces for sport and recreation to make an important contribution to health and well-being of communities. If required, an appropriate contribution will be provided for education provision and community facilities. Open and children s play space is provided on site, in accordance with the local and national guidelines Paragraph 75 requires the protection of PROW and access, and encourages opportunities to provide better facilities for users, by example, by adding links to existing rights of way networks. The proposed development accords with these objectives, specifically linking the residential development to the surrounding public footpath network and including a potential future link to Bloors Lane Community Woodland The Illustrative Site Layout Plan (Drawing. No ) submitted to accompany the application demonstrate how the development would comply with the objectives of Theme 8, outlined above and in particular demonstrates that a significant amount of publicly accessible open space would be provided on the Site, and the connections to the public footpath network surrounding the Site. Theme 10: Meeting the challenge of climate change, flooding and coastal change (Paras ) 4.32 Paragraph 101 requires that development be directed to reasonably available and appropriate sites with a low probability of flooding and Para 103 requires that flood risk should not be increased elsewhere A Flood Risk and Foul and Surface Water Drainage Assessment (Weetwood) are submitted with the application and as explained in Section 5 demonstrates that these policies objectives will be met. It demonstrates the overall sustainable drainage (SUDS) strategy for the site. Theme 11: Conserving and enhancing the natural environment (paras ) 4.34 The NPPF sets out the planning framework for conserving and enhancing the natural environment. Paragraphs 109 summarises that as: Protecting and enhancing valued landscapes, geological conservation interests and soils; Recognising the wider benefits of ecosystem services; 27239/A5/JM/ja 18 October 2017

24 Planning Policy Context Minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government s commitment to halt the overall decline in biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures; Preventing both new and existing development from contributing to or being put at an unacceptable risk from, or being adversely affected by unacceptable levels of soil, air, water or noise pollution or land instability; and Remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate Paragraph 111 specifies that planning decisions should encourage the effective use of land by re-using land that has been previously developed (brownfield land), provided that it is not of high environmental value Paragraph 112 requires local planning authorities to take into account the economic and other benefits of the best and most versatile agricultural land. An accompanying Agricultural Land Classification Report (RSK ADAS Ltd) identifies that the Site is not currently used for agriculture and most of the site would require significant remediation prior to bringing it back into production due to the size and age of trees which are growing in blocks across the Site Paragraph 118 advises, inter alia, when determining planning applications, local planning authorities should aim to conserve and enhance biodiversity by applying the following principles: Opportunities to incorporate biodiversity in and around developments should be encouraged The proposed development fully accords with this objective by way of increasing the new biodiversity on Site. Theme 12: Conserving and enhancing the historic environment (Paras ) 4.39 Paragraph 128 seeks to ensure that when determining applications, LPA s should require an applicant to describe the significance of any heritage assets affected. Paragraph 132 of the NPPF directs that when considering the impact of development on a designated heritage asset s significance, great weight should be given to the asset s conservation. The more important the asset, the greater the weight should be /A5/JM/ja 19 October 2017

25 Planning Policy Context 4.40 When a development would lead to substantial harm to or total loss of a designated heritage asset s significance, LPAs should refuse consent unless it can be demonstrated that the substantial harm or loss is necessary to achieve substantial public benefits that outweigh that harm or loss (para. 133). Where a development would lead to less than substantial harm, this should be weighed against the public benefits of the proposal (para. 134). Decision- taking (para s ) 4.41 The NPPF directs that LPAs should approach decision making in a positive way (Para. 186). LPAs should therefore work positively with applicants to find solutions and to deliver sustainable developments that secure improvements to the economic, social and environmental conditions of an area Pre-application engagement and front loading is positively supported as part of involving the efficiency and effectiveness of the planning system. Wherever possible early engagement with Officers, statutory consultees, key stakeholders and the local community is encouraged (Para. 188). The scheme has successfully undertaken extensive consultation, further details of which are set out in the supporting Statement of Community Involvement (SCI) Para. 196 confirms the NPPF is a material consideration in planning decisions and para. 197 advises that LPAs should apply the presumption in favour of sustainable development. Para s confirm planning conditions and obligations should be sought where necessary and relevant. For obligations this means being necessary, directly related to the development and fairly and reasonably related in scale and kind to the development. For Conditions, they should be relevant, enforceable, precise and reasonable in all other respects. Annex 1: Implementation (para s ) 4.44 The NPPF reiterates the role of the plan-led system, but also the need to have regard to the content of the NPPF in decision-making. Para 214 advises that full weight should be given to adopted Local Plan policies since 2004, but only for a 12-month period (i.e. up to 27 March 2013) Thereafter, and in all other cases, including Medway Council s case, Para 215 advises that due weight should be given to relevant policies in existing plans according to their degree of consistency with the Framework i.e. where a Local Plan does not confirm with the NPPF, it will hold little or no weight for decision-making after this 12-month deadline /A5/JM/ja 20 October 2017

26 Planning Policy Context 4.46 Paragraph 216 expressly sets out that from the day of publication, decision takers will give weight to relevant emerging policies (unless material considerations indicate otherwise). The weight attached to the emerging policies should take into account the stage of preparation, the extent to which objections have been resolved and the degree of consistency with relevant policies in the emerging plans In response to this, the Medway Local Plan (MLP) precedes the NPPF by eight years and is therefore largely out of date. The policies therefore hold limited weight in the planning balance according to their degree of consistency with the NPPF (Para. 215). iii) Planning Practice Guidance 4.48 The Planning Practice Guidance (PPG, 06 March 2014) builds on the principles within the NPPF and provides further detailed technical guidance, with reference to relevant legislation and other guidance. The relevant sections of the PPG which relate to the planning application are listed below Five Year Housing Land Supply Paragraph 30 [Reference ID: ] reinforces the requirement of the NPPF for LPA s to identify and update annually a supply of specific deliverable sites sufficient to provide 5-years worth of housing against their housing requirements Deliverable sites for housing could include those that are allocated in the Development Plan or sites with planning permission. However, this is not a prerequisite for a site being deliverable within 5-years and LPAs need to provide robust up-to-date evidence accordingly. The size of sites will be an important factor in identifying whether a site is deliverable within the first 5- years, as is the time required to commence development on site and realistic build out rates (Reference ID: ) LPAs should aim to deal with any past under-supply of housing within the first 5-years where possible, or work with neighbouring authorities under the Duty to Cooperate (Reference ID: ) /A5/JM/ja 21 October 2017

27 Planning Policy Context 4.52 Noise Section ID30 of the PPG adds additional, more detailed guidance on noise to that contained in the NPPF. The guidance recognises that noise is a relevant consideration for development within areas exposed to existing noise [Reference ID: ]. The guidance relates closely to the National Policy Statement for Noise (Defra) and advises that LPA s decision taking should take account of the acoustic environment. However, paragraph 002 [Reference ID: ] recognises that noise should not be considered in isolation, separate from economic, social and environmental dimensions of proposed development Air Quality Section ID32 provides further information on, and sets out the circumstances in which, air quality might be relevant to planning decisions, including where development is likely to impact on an area where air quality is poor, or if the development is likely to adversely impact upon the implementation of air quality strategies and action plans. Emphasis is placed on consultation with the planning authority to determine whether there are any local issues with the potential to affect the scope of an air quality assessment. Typical air quality mitigation measures are outlined, including design and layout, promotion of sustainable travel modes, the use of green infrastructure, control of dust and emission from construction and the use of planning conditions and funding obligations to off-set any significant impacts Conserving and Enhancing the Historic Environment Section ID18a of the PPG relates to the historic environment and complements paragraphs of the NPPF. It states that protecting and enhancing the historic environment is an important component of the NPPF s drive to achieve sustainable development. Paragraph 003 [Reference ID: 18a ] states the conservation of heritage assets in a manner appropriate to their significance is a core planning principle. Heritage assets are an irreplaceable resource and effective conservation delivers wider social, cultural, economic and environmental benefits Design Section ID26 of the PPG sets out the importance of good design. It advocates the need for quality design and confirms that this is an integral part of achieving the fundamental objective of sustainable development. As a core planning principle, decision takers should always seek to secure high quality design. Paragraph 15 [Reference ID: ] advises that well designed new places should: Be functional; Support mixed uses and tenures; Include successful public spaces; Be adaptable and resilient; Have a distinctive character; 27239/A5/JM/ja 22 October 2017

28 Planning Policy Context Be attractive; and Encourage ease of movement Flooding Risk and Coastal Change Section ID7 of the PPG provides detailed technical guidance on the requirements of flood risk assessments, requiring developers and applicants to consider flood risk to and from the development site. The broad approach of assessing, avoiding, managing and mitigating flood risk should be followed and the PPG requires the use of sustainable drainage systems Natural Environment Section ID8 of the PPG highlights that Local Authorities have a duty under Section 40 of the Natural Environment and Rural Communities Act 2006, to have regard, in the exercise of their functions, to the purpose of conserving biodiversity. The PPG identifies that a core principle for planning is that it should contribute to conserving and enhancing the natural environment and reducing pollution Travel Plans and Transport Assessment/Statements Section ID42 of the PPG relates to Travel Plans, Transport Assessments and Statements in relation to decision-taking and how they can be used to promote the most sustainable forms of transport. It states that Travel Plans, Transport Assessments and Statements can positively contribute to: Encouraging sustainable travel; Lessening traffic generation and its detrimental impacts; Reducing carbon emissions and climate impacts; Creating accessible, connected, inclusive communities; Improving health outcomes and quality of life; Improving road safety; and Reducing the need for new Development to increase existing road capacity or provide new roads. iv) The Development Plan 4.59 The Site is located within Medway Council. Therefore, relevant parts of the development plan of the authority are assessed. a) Medway Local Plan The Development Plan comprises the Saved Policies of the adopted Medway Local Plan (MLP) which was adopted in March 2003 (14 years ago) and sets out the planning strategy and policies for the plan period It is therefore largely out-of-date /A5/JM/ja 23 October 2017

29 Planning Policy Context Compliance with the NPPF 4.61 In a report approved my Medway Planning Committee on 19 February 2014 Compliance with the National Planning Policy Framework (2014) Medway Council considered the implications of the NPPF on the Medway Local Plan Policies. There were three broad areas where there was considered to be a conflict, Employment and Economic Development, Retail and Town Centres and Countryside Protection. The following was identified, regarding Policies of relevance to this proposal: Policies considered not consistent : BNE3: Noise Standards Policies with significant issues : BNE25: Development in the Countryside Policies which are partially consistent : S6: Planning Obligations BNE2: Amenity Protection BNE34: Areas of Local Landscape Importance H1: New Residential Development H5: High Density Housing L4: Provision of Open Space in New Residential Developments L10: Public Rights of Way T1: Impact of Development 4.62 Where a Policy is listed as partially consistent this can be due to several reasons, as follows: The Policy is consistent enough to be applied in decision making, but may be challengeable in some circumstances; Parts of the Policy are consistent where other aspects are not; Whilst the Policy is broadly consistent, it needs to be read in the context of more upto-date policies set out in the NPPF /A5/JM/ja 24 October 2017

30 Planning Policy Context 4.63 The Saved Policies of the adopted Local Plan considered relevant to the development proposals include the following: Policy S1: Development Strategy states that the development strategy for the plan area is to prioritise re-investment in the urban fabric. Policy S2: Strategic Principles states that the implementation of the development strategy within the Local Plan will focus on: (i) (ii) (iii) maintaining and improving environmental quality and design standards; a sustainable approach to the location and mix of new development, to provide local communities with a range of local facilities, (including transport measures to serve development and sensitivity in the use of energy and natural resources); and, the adoption of a sequential approach to the location of major people and traffic attracting forms of development, including retailing, leisure, educational and health facilities. Policy S4: Landscape and Urban Design states that a high quality of built development will be sought from new development with landscape mitigation where appropriate. The Development should respond to the context, reflecting a distinct local character. Policy S6: Planning Obligations [recognised by the Council as being partially consistent with the NPPF] states that the Council will set conditions on planning permissions or seek to enter into a legal agreement with developers to provide for new physical infrastructure, social recreational and community facilities (including education facilities) and environmental mitigation or compensation measures where mitigation is impossible or inadequate on its own, where the need for these arises directly from the development concerned. Policy BNE1: General Principles for Built Development sets out the general principles of built development (scale, massing, layout, siting and materials). Development should provide well structured, practical and attractive areas of open space where appropriate and respect the visual amenity of the surrounding area /A5/JM/ja 25 October 2017

31 Planning Policy Context Policy BNE2: Amenity Protection [recognised by the Council as being partially consistent with the NPPF] states that all development should secure the amenities of its future occupants, and protect those amenities enjoyed by nearby and adjacent properties. The design of development should have regard to: (i) privacy, daylight and sunlight; (ii) noise, vibration, light, heat, smell and airborne emissions; and (iii) activity levels and traffic generation. Policy BNE3: Noise Standards [recognised by the Council as being not consistent with the NPPF] Residential development should be designed to minimise noise levels within gardens and/or amenity areas provided by that development. This policy is not considered by the Council to be consistent with the NPPF as the requirements of the Policy (i.e. the required noise levels) are not consistent with those in the NPPF and Noise Policy Statement for England. Policy BNE6: Landscape Design states that major developments should include a structural landscape scheme to enhance the character of the locality. Detailed landscaping schemes should be submitted before development commences and should include matters such as easily maintainable open spaces, planting species/sizes, design and materials of hard landscaping measures, retain important existing landscaping features, and support wildlife by the creation or enhancement of semi-natural habitats. Policy BNE7: Access for All states that development should be designed so that access to buildings and external circulation areas meets the needs of people with disabilities, the elderly and people with young children. Policy BNE8: Security and Personal Safety states that the design and layout of development should seek to maximise personal safety and the security of property. Policy BNE23: Contaminated Land states that development on land known or likely to be contaminated or affected by adjacent or related contamination must be accompanied by the findings of a detailed site examination to identify contaminants and the risks that these might present to human health and the wider environment. The policy also requires remedial measures to be satisfactorily implemented before the development is occupied. Policy BNE24: Air Quality states that development will not be permitted where it unacceptably impacts on the surrounding area, taking into account the cumulative effects of other proposed or existing sources of air pollution /A5/JM/ja 26 October 2017

32 Planning Policy Context Policy BNE25: Development in the Countryside [recognised by the Council as having significant issues in terms of consistency with the NPPF] seeks to ensure that development in the countryside is only permitted, of relevance, if: i) It maintains and where possible enhances character, amenity and function of the countryside and offers a realistic chance of access by a range of transport modes; and is either; ii) Allocated for that use; or iii) A re-use of adaption of an existing building that would be in keeping with Policy BNE27. The Council has acknowledged that this policy has significant issues in consistency with the NPPF, including the requirement of the NPPF to encourage sustainable patterns of land use and development including the re-use of previously developed land. Policy BNE34: Areas of Local Landscape Importance [recognised by the Council as being partially consistent with the NPPF] states that development within ALLI will only be permitted if: i) It does not materially harm the landscape character and function of the area; or ii) The economic and social benefits are so important that they outweigh the local priority to conserve the area s landscape. Development within an ALLI should be sited, designed and landscaped to minimise harm to the area s landscape character and function. Policy BNE37: Wildlife Habitats states that development that would cause a loss, directly or indirectly, of important wildlife habitats or features not protected by Policies BNE35 and BNE36 will not be permitted unless there is an overriding need for the development that outweighs the importance of the wildlife resources; that the development is designed to minimise the loss involved; and appropriate compensatory measures are provided. Policy BNE39: Protected S pecies states that development will not be permitted if protected species and/or their habitat will be harmed, and conditions should be used to safeguard such species. Conditions will be attached, and/or obligations sought, to ensure that protected species and/or their habitats are safeguarded and maintained. Policy BNE42: Hedgerow R etention requires important hedgerows are retained and protected as part of development proposals /A5/JM/ja 27 October 2017

33 Planning Policy Context Policy BNE43: Trees on Development Sites requires that development should seek to retain trees, woodlands, hedgerows and other landscape features that provide a valuable contribution to local character. Policy BNE44: Community Woodlands states that development that would prejudice the implementation of the proposed community woodlands [in this case Bloors Lane Community Woodland] will not be permitted. Policy BNE48: Agricultural Land states that development that would cause a loss of the best and most versatile agricultural land (MAFF grades 1, 2 and 3a) will not be permitted except when exceptionally justified in cases such as a demonstrated case of overriding need, or where there is a lack of other suitable development opportunities on PDL. Policy H3: Affordable Housing requires affordable housing to be sought as a proportion of residential developments of a substantial scale where a need has been identified. A substantial scale includes sites within an urban area which include 25 dwellings or more, or where the site area is 1 hectare or more. Policy H5: High Density Housing [recognised by the Council as being partially consistent with the NPPF] states that housing proposals at low densities will not be permitted in, or close to: town centres, near existing or proposed public transport access points or along routes capable of being well served by public transport and which are close to local facilities. Policy H10: Housing Mix on sites larger than one hectare, where residential development is acceptable in principle, the provision of a range and mix of house types and sizes will be sought. This will include smaller units of accommodation suited to the needs of one and twoperson households, the elderly or persons with disabilities and housing that can be adapted for such use in the future. Policy L4: Provision of Open Space in New Residential Developments [recognised by the Council as being partially consistent with the NPPF] where there is a proven deficiency, residential development proposals shall make open space provision, within an agreed timescale, in accordance with the following: 27239/A5/JM/ja 28 October 2017

34 Planning Policy Context i) Residential development likely to be occupied by 100 people or more shall include well located local open space for formal recreation on-site at a standard equivalent to 1.7 hectares per 1,000 population and open space for children s play and casual recreation on-site at a standard equivalent to 0.7ha per 1,000 population. Provision of some or all of the formal open space off-site or the improvement or extension of an existing offsite facility will be permitted where the Council is satisfied that this would be a better alternative; ii) Residential developments likely to be occupied by between 100 people should include well located open space for children s play and casual recreation on-site at a standard equivalent to 0.7 hectares per 1,000 population. Policy L10: Public Rights of Way [recognised by the Council as being partially consistent with the NPPF] states that development which would prejudice the amenity, or result in the diversion or closure, of existing public rights of way will not be permitted, unless an acceptable alternative route with comparable or improved amenity can be provided. Policy T1: Impact of Development [recognised by the Council as being partially consistent with the NPPF] requires that the impact of a proposed development be assessed in relation to existing highway network capacity, accidents, HGV movements and timings of movements. Policy T2: Access to the Highway requires that new development proposals will need to achieve satisfactory access to a standard acceptable to the highway authority, and which will not compromise highway safety. Policy T3: Provision for Pedestrians requires development proposals to provide attractive and safe pedestrian access. Policy T4: Cycle Facilities requires secure cycle parking and associated facilities to be provided in accordance with the Council s adopted cycle parking standards. Policy T11: Development Funded Transport Improvements states that the LPA will be prepared to enter into legal agreements with developers for the improvement of the transport network. This may involve bringing forward a scheme already in the transport programme or it may involve contributions towards the provision of facilities for cycling, walking or public transport, in line with the guidance in PPG13 (now the NPPF) /A5/JM/ja 29 October 2017

35 Planning Policy Context Policy T12: Traffic Management states that road layouts within new developments will need to be designed with appropriate traffic management measures to help limit vehicle speeds and improve safety for all road users. Policy T13: Vehicle Parking Standards states that development proposals shall be in accordance with the adopted standards. Policy T14: Travel Plans will be required for all developments which require a transport assessment or as otherwise required by the LPA s vehicle parking standards. Policy CF12: Water Supply Development proposals must ensure that adequate measures are undertaken to protect surface and groundwater resources. v) Emerging Medway Local Plan MC is in the process of preparing a new Local Plan for the period , which will replace the Medway Local Plan (2003). This is in a formative stage, with the first stage Issues and Options consultation being held between January and February A second stage Regulation 18 Development Options consultation was undertaken between January and April The Regulation 18 Development Options consultation document sets out the Council s housing requirement of 29,463 dwellings (1,281 dpa) for the plan period ( ) and provides four potential scenarios for a development strategy for the Local Plan, as follows: Scenario 1: Maximising the potential for urban regeneration; Scenario 2: Suburban expansion; Scenario 3: Hoo Peninsula Focus; and Scenario 4: Urban Regeneration and a Rural Town Medway Council s published Local Development Scheme (December 2016) sets out the Council s intentions to publish a draft Regulation 19 Plan in Winter 2017/2018, submission for examination in Spring 2018 and Adoption in early The emerging Local Plan is still at a formative stage, and as such should be afforded limited weight at this current time, however, there is a clear direction of travel in terms of the urgent need for new homes in Medway. The emerging Local Plan is also supported by an important evidence base (including the SHENA and SLAA) as discussed further below /A5/JM/ja 30 October 2017

36 Planning Policy Context vi) Development Plan/Housing Land Supply 4.67 MC recognises that it is unable to meet its 5-year housing land supply (HLS). The latest MC Annual Monitoring Report (December 2016) identifies that in 2015/16 there were 533 new residential units completed, below the annual requirement of 1,000 units. Furthermore, the MC Annual Monitoring Report identifies long-standing deficits in housing supply, cumulating in an overall deficit of 1,820 units for the period of In a recent appeal for Land at Gibraltar Farm, Hempsted (appeal reference APP/A2280/W/16/ decision dated 6 March 2017) it was common ground between the parties that a 5-year housing land supply cannot be demonstrated and the supply was identified as being in the range of years On this basis, it is evident that MC cannot demonstrate a 5-year housing land supply. The Local Plan is therefore out-of-date in accordance with paragraph 49 of the NPPF, and the NPPF presumption in favour of sustainable development should be afforded full weight as set out in NPPF Paragraph 14 second bullet. vii) Strategic Housing and Economic Needs Assessment (SHENA) (March 2015) 4.70 Medway Council and Gravesham Borough Council jointly commissioned a Strategic Housing and Economic Needs Assessment (SHENA) (2015) to identify development needs for housing, employment and retail land. It was jointly prepared because of the degree of interdependence in housing and employment markets. Some of the outcomes for Medway are set out below: 2013 internal migration flows out of Medway reveal the strongest relationship with Maidstone, Swale and Tonbridge and Malling; The analysis of Medway s net migration gains and losses suggests that Medway has a closer local relationship with authorities within the Kent region than Gravesham. Although there is a relationship with London evident in net migration gains; The latest 2012-based SNPP forecast a population of 326,800 by 2037 in Medway, an increase of 21.8%; Based on the latest 2012-based household projections for Medway there are forecast to be 139,900 households (29% increase); and Levels of population and household growth will have significant implications for the housing, employment and retail requirements for both authorities /A5/JM/ja 31 October 2017

37 Planning Policy Context viii) Strategic Land Availability Assessment (SLAA) (January 2017) 4.71 To support the preparation of the new Local Plan, Medway Council has published a Strategic Land Availability Assessment (SLAA) in January 2017 focussing on the potential for new residential development within its administrative area. A total of 53 sites were deemed to be suitable, available and achievable for residential development amounting to a potential for 5,980 new residential units across Medway Importantly, the Site Berengrave Nursery, Rainham (Site Reference: 817) was assessed as part of the SLAA process as being suitable and available for residential development with an overall capacity of 151 units (Appendix E) /A5/JM/ja 32 October 2017

38 Planning Analysis 5.0 PLANNING ANALYSIS 5.1 This section of the report sets out an assessment of the proposed development against the issues raised in the relevant planning policy and guidance. A topic based approach is taken in respect of the prevailing planning considerations, with due regard to the earlier rehearsed planning policies at National and Local level. 5.2 In compiling this application submission it has been possible to identify the following overarching planning considerations: i) Principle of Sustainable Development; a) Presumption in Favour of Sustainable Development; b) Development Plan/Housing Land Supply; c) Prematurity; ii) Residential Development; a) Suitability of the Site for Residential Development; b) Affordable Housing; c) Housing Mix; d) Housing Capacity/Density; iii) Definition of Sustainable Development; iv) Design and Layout; v) Open Space; vi) Transport and Traffic; vii) Flooding and Drainage; viii) Landscape and Visual; ix) Ecology; x) Arboriculture; xi) Agricultural Land Classification; xii) Archaeology; xiii) Noise; xiv) Air Quality; xv) Contamination; xvi) Section 106 Heads of Terms 27239/A5/JM/ja 33 October 2017

39 Planning Analysis i) Principle of Sustainable Development a) Presumption in Favour of Sustainable Development 5.3 As set out in the previous section of this Statement, a presumption in favour of sustainable development is at the heart of the NPPF. The Development Plan is the starting point for the consideration of planning applications, and planning applications must be determined in accordance with it, unless material considerations indicate otherwise. The NPPF is a material consideration (para. 13). b) Development Plan/ Housing Land Supply 5.4 The adopted Local Plan only deals with a housing requirement up to 2006 and Medway Council has acknowledged that it cannot demonstrate a 5-year supply of housing within its formal preapplication response (Appendix C). 5.5 NPPF (para. 49) states: Housing applications should be considered in the context of the presumption in favour of sustainable development. Relevant policies for the supply of housing should not be considered up-todate if the local planning authority cannot demonstrate a five-year supply of deliverable housing sites. (Our emphasis added) 5.6 In accordance with para. 49 of the NPPF, MC s policies relevant for the supply of housing are therefore out-of-date and the presumption in favour of sustainable development applies on the basis that no Footnote 9 designations apply in this instance. 5.7 Para. 14 of the NPPF states that, where the development plan is absent, silent or relevant policies are out-of-date, LPAs should grant permission unless: Any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in the Framework taken as a whole; or Specific policies in this Framework indicate development should be restricted. 5.8 The Site is located in a sustainable location in close proximity (circa 1.05 km) to the centre of Rainham town centre with its respective services, community facilities and public transport links, and contributes to the economic, social and environmental roles of sustainable development as set out in the NPPF (para. 7) and as demonstrated elsewhere in this Statement. The proposed development therefore accords with para. 14 of the NPPF /A5/JM/ja 34 October 2017

40 Planning Analysis 5.9 In order to assist the National economy, the Government is committed to increasing the overall level of housing, and the NPPF (para. 47) sets out the measures LPAs should pursue in order to boost significantly the supply of housing. Such measures include the use of an objectively assessed evidence base and the identification of a 5-year supply of deliverable sites (with an additional buffer of 5% to ensure greater choice and competition) As identified in its pre-application response, MC acknowledges that it does not have a 5-year supply of deliverable housing sites based on its most recent housing trajectory (as of 31 March 2016). Most recently, this under-supply position was confirmed in a recovered appeal for Land at Gibraltar Farm, Hempsted (appeal reference APP/A2280/W/16/ , decision dated 6 March 2017) where it is stated: The Secretary of State has carefully considered the Inspectors analysis and reasoning [ ]. He notes that the main parties agree that a five-year housing land supply cannot be demonstrated and the Council acknowledges a supply in the range of 2.21 to 2.79 years. The appellant considers that even that level is optimistic and the Inspector considers that the housing land supply is significantly lacking. Overall the Secretary of State agrees with the Inspector s conclusions, that the shortfall in five year housing land supply is so great and the pressure on sites is so significant, that it is inevitable that Greenfield land will have to be developed The Site is capable of delivering housing in the short-term and would therefore positively contribute towards the 5-year supply position, providing Medway with a more robust position whilst work continues on the emerging Local Plan Importantly, the technical information submitted in support of the application demonstrates that there are no adverse impacts of development that would significantly or demonstrably outweigh the benefits. The Site has also been recognised as being suitable and available for residential development by Medway Council Officers within published SLAA (January 2017) In conclusion, para. 49 of the NPPF is engaged in this instance as it has been demonstrated that Medway Council cannot demonstrate a 5-year supply of deliverable housing sites and therefore the relevant policies for the supply of housing should not be considered up-to-date. Therefore, Policies BNE25 which relates to development in the open countryside, and BNE34 which relates to the ALLI designation, which seek to restrict housing supply in Medway, must be considered out-of-date and should only be afforded limited weigh. In accordance with NPPF para. 14, planning permission should therefore be granted unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole /A5/JM/ja 35 October 2017

41 Planning Analysis 5.14 In terms of Policy BNE34 (in relation to the ALLI designation), whilst this policy should be afforded limited weight owing to the Council s lack of 5-year housing land supply, the policy does allow for new development in an ALLI if the social and economic benefits of the proposal outweigh the local priority to conserve the area s landscape. The significant social and economic benefits of the proposed scheme are addressed in detail throughout this Statement. c) Prematurity 5.15 Para. 216 of the NPPF states, from the day of publication (27 March 2012), decision-takers may also give weight (unless other material considerations indicate otherwise) to relevant policies in the emerging plans according to: The stage of preparation of the emerging plan (the more advanced the preparation, the greater the weight that may be given); The extent to which there are unresolved objections to relevant policies (the less significant the unresolved objections, the greater the weight that may be given); and The degree of consistency of the relevant policies in the emerging plan to the policies in the Framework (the greater the weight that may be given) As outlined above, a new Medway Local Plan ( ) is currently being prepared although this is still at a formative stage. The first stage Issues and Options consultation was held between January and February A second stage Regulation 18 Development Options consultation was undertaken between January and April The most up-to-date Local Development Scheme (December 2016) sets out the Council s intentions to publish a draft Regulation 19 Plan in Winter 2017/2018, with submission for examination in Spring 2018, and Adoption in early In having regard to the issue of prematurity, and whilst the NPPF reiterates the role of the plan-led system, it also highlights the weight to be given to the content of the NPPF in decision making. Para. 214 advises that full weight should be given to the adopted Local Plan policies since 2004, but only for a 12-month period (i.e. up to 27 March 2013). Thereafter, and in all other cases, para. 215 advises of the increasing weight to be given to the policies contained in the NPPF Para. 216 of the NPPF states, from the day of publication (27 March 2012), decision-takers may also give weight (unless other material considerations indicate otherwise) to relevant policies in the emerging plans according to the stage of preparation; the extent to which there are unresolved objections; and the degree of consistency of relevant policies to the NPPF /A5/JM/ja 36 October 2017

42 Planning Analysis 5.19 The proposed development (of 121 dwellings represents only 0.5% of the OAN housing target of 24,000 dwellings over the period ) is not considered to be so significant so as to prejudice the scale and location of development through the Local Plan. Nevertheless, the Site would provide for a meaningful contribution towards the present 5-year requirement providing the Borough with a more robust position whilst work continues on the emerging Local Plan In this context, it is also important to consider that the Site has been assessed as being suitable and available for residential development of up to 151 dwellings within the Council s recently published SLAA (January 2017). The published SLAA is, of course, an important direction of travel of future development land allocations within the emerging Local Plan. ii) Residential Development a) Suitability of the Site for Residential Development 5.21 The Site is recognised within the recently published Medway Council SLAA (January 2017) [Site 817] as being suitable and available for the provision of up to 151 residential dwellings due to its location and characteristics (see extract if SLAA appraisal at Appendix E) The Site will contribute to the delivery of developable housing land where there is currently a clearly evidenced shortfall. The proposal is well considered and achieves a number of other key benefits. A key focus of current National policy is the delivery of much needed housing. The proposed development would therefore deliver much needed market and affordable housing in a location identified as suitable and available for development The Site is well located insofar as it immediately adjoins the existing residential area of Rainham, and existing access to public transport and major road networks. It is located in a in a sustainable location close to public transport services including Rainham Railway Station (1.05 km) and nearby bus stops (being situated some 250m, 860m and 960m respectively from the Site). In addition, the proposals include new connectivity from the Site to the surrounding Public Footpath network and onto Berengrave Lane, both of which will enhance and complement the integration of the future residents with the existing community The Site, as an existing retail Nursery, comprises land that has previously been developed for associated retail Nursery uses including sales, storage, growing and other ancillary buildings. The Site therefore constitutes previously developed land, in part, as defined by the NPPF (Annex 2): 27239/A5/JM/ja 37 October 2017

43 Planning Analysis Land which is or was occupied by a permanent structure, including the curtilage of the developed land (although it should not be assumed that the whole of the curtilage should be developed) and any associated fixed surface infrastructure. This excludes land that is or has been occupied by agricultural or forestry buildings; land that has previously been developed for minerals extraction or waste disposal by landfill purpose where provision for restoration has been made through development control procedures; land in builtup areas such as private residential gardens, parks, recreation grounds and allotments; and land that was previously-developed but where the remains of the permanent structure or fixed surface structure have blended into the landscape in the process of time. NPPF (Annex 2) A core planning principle of the NPPF (Para. 17) is to encourage the effective use of land by reusing land that has been previously developed (brownfield land), provided that it is not of high environmental value. Development of the Site for the purposes specified in this Outline application will accord with the overarching objectives of the NPPF in this regard Importantly, Rainham is referred to in the MC Development Options Consultation as potentially being suitable for a sustainable urban expansion to complement urban regeneration priorities in central Medway. This planned suburban expansion around Rainham represents development Option 2: Suburban Expansion as identified in the Development Options document consulted on between January and May New development focussing around Rainham is therefore a clearly direction of travel in the emerging Local Plan. b) Affordable Housing 5.27 The application proposes up to 25% affordable housing (a maximum of 30no. dwellings based on 121no dwellings being provided on the Site). The specific layout of affordable units is not fixed at this stage due to the Outline nature of the application, however, the intention is to include affordable units throughout the Site to ensure they are integrated with market housing. The final mix of affordable housing units is also not fixed at this Outline stage, with the final mix responding to design and market considerations at any subsequent Reserved Matters stage The scheme will provide for a suitable mix and tenure of affordable dwellings to meet the local needs. The scheme proposals therefore accord with the requirements of Local Plan Policy H3. c) Housing Mix 5.29 The Outline development proposals include up to 121 dwellings, including the provision of 25% affordable housing (a maximum of 30no. units) being provided within the Site /A5/JM/ja 38 October 2017

44 Planning Analysis 5.30 In respect of both open market and affordable housing, it is proposed that the housing mix is not set as part of the Outline application in order to provide greater flexibility at the Reserved Matters stage. However, the emphasis of the scheme as a whole will be on 2, 3 and 4 bed dwellings, together with some 1 and 2 bed flats to meet local housing need The scheme will provide for a suitable housing mix throughout the Site, in accordance with the advice contained in paragraph 50 of the NPPF, and responding to the requirements of Local Plan Policy H3. Following changing requirements at a National policy level (i.e. Starter Homes) it is intended that the affordable housing tenure mix will be agreed at a Reserved Matter stage. d) Housing Capacity/Density 5.32 The overall gross density across the Site will be 21dph, with a net density of 34 dph (based on the developable site area shown within the Parameter Plan of 3.6ha). The illustrative site layout plan provides for a range of densities across the Site including medium densities will be located along the primary street hierarchy routes with lower densities towards the Site boundaries to create a softer edge of the development. iii) Definition of Sustainable Development 5.33 The NPPF (March 2012) provides the Government s latest definition of sustainable development, which included reference to: the purpose of planning is to help achieve sustainable development [and] development means growth. (NPPF, Ministerial Foreword, Gregg Clark MP) 5.34 As directed in para. 6 of the NPPF, paras. 18 to 219 should be taken as a whole to constitute the Government s view of what sustainable development means in practice for the planning system Para. 7 of the NPPF identifies that there are three dimensions to sustainable development, being economic, social and environmental. It is recognised that these roles should not be undertaken in isolation, because they are mutually dependant: Economic growth can secure higher social and environmental standards, and well-designed buildings and places can improve the lives of people and communities. Therefore, to achieve sustainable development, economic, social and environmental gains should be sought jointly and simultaneously through the planning system. (NPPF, para. 8) 27239/A5/JM/ja 39 October 2017

45 Planning Analysis 5.36 The NPPF stresses the importance of supporting growth and creating sustainable communities. The proposal will have long lasting economic benefits by providing housing, open space and maintaining vibrancy of local communities and facilities. The economic benefits of the scheme proposals are set out within the Economic Benefits Statement (Barton Willmore, October 2017) as contained at Appendix D When considering the immediate economic benefits, along with the broader social and environmental benefits resulting from the proposed scheme, it is considered that the development accords fully with the policy objectives of the NPPF, namely: An Economic Role: 5.38 The main economic benefits of the scheme, as set out in the accompanying Economic Benefits Statement, can be summarised as follows: Construction Phase: Construction jobs generated monthly 65 Indirect jobs generated monthly 39 Direction Construction Gross Value Added (GVA) - 9.5m Indirect GVA - 5.9m Completed Development/Operational Phase Resident population generated 304 o Of which are economically active 161 o Of which are assumed to be in employment 152 GVA generated per annum by resident population in employment - 6.8m Additional commercial expenditure per annum 2.3m o Of which convenience goods 0.6m o Of which comparison goods 0.9m o Of which leisure goods and services 0.8m New Homes Bonus 0.7m Council Tax per annum 0.2m 27239/A5/JM/ja 40 October 2017

46 Planning Analysis A Social Role: 5.39 The main social benefits of the scheme can be summarised as follows: The creation of up to 121 dwellings (including 25% affordable housing) will support the creation of strong, vibrant and healthy communities. This is significant in the light of MC s lack of 5-year housing land supply; Residential development on the Site would create unique choice and opportunity in the housing market and the range of housing that could be built; The provision of affordable housing will increase the Council s supply of affordable homes and help reduce inequalities; The provision of open space on Site contributes to increasing the quality of the environment, providing a range of social experiences; 2.2ha of the Site will be used for open space and landscaping planting (approximately 38% of the total Site area), and will be in easy walking distance of the new homes and existing community, and thereby encourage the development of healthy communities; The proposed development will link directly to the existing surrounding Public Footpath network, with a potential future pedestrian link to the Bloors Lane Community Woodland; and New family housing will provide the means to supplement local community services. An Environmental Role: 5.40 The main environmental benefits of the scheme can be summarised as follows: The development would make effective use of land by re-using land that is previously been developed (brownfield land) in connection with the retail use of the Site as a Nursery; The Site is not within an area of flood risk (located in Flood Zone 1); Development of the Site with a high quality sensitive scheme provides the opportunity to significantly improve the natural environment both in terms of landscape and ecology; An accessible location within close proximity to existing services and public transport in Rainham; Promotion of a range of transport modes to future residents via a Travel Plan, reducing the reliance on the private car; and 27239/A5/JM/ja 41 October 2017

47 Planning Analysis Provision of 2.2 hectares of quality open space and landscape planting (approximately 38% of the total site area) including landscaped and shared surface main and secondary streets, linkages to the existing Public Footpath network and a possible future pedestrian link to the adjoining Bloors Lane Community Woodland These benefits are examined more fully in the remainder of this Statement. iv) Design and Layout 5.42 The application is submitted in Outline and as such not all of the detailed design elements are for determination at this stage. However, the proposed development takes into account the advice contained in the NPPF which places great importance on the design of the built environment (para. 56), conserving and enhancing the natural environment (para. 109) and conserving and enhancing the historic environment (para. 131) The Illustrative Site Layout Plan (Drawing ) and parameters of the scheme have been carefully prepared and the design evolution of the scheme has been informed by both a local community consultation and a detailed pre-application discussion with MC a summary of which can be found within the accompanying Statement of Community Involvement (Barton Willmore) The accompanying Design and Access Statement (Richards Urban Design) establishes the quality of the proposed development and describes the design process taking into account consideration of issues such as existing trees and vegetation, local character, massing, height, access, etc The proposed development will provide for a high-quality development in terms of buildings, urban form and spaces, which is both distinctive and in keeping with the character of the area with a suitable overall gross density of approximately 21 dwellings per hectare within the Site. The layout of the development would ensure that it would respect the residential amenity of existing residential properties It can therefore be concluded that the proposal would accord with the provisions of the relevant design and character based policies, contained within the NPPF (including Paras. 50 and 56-59) and Saved Policies BNE1 and BNE2 of the Medway Local Plan /A5/JM/ja 42 October 2017

48 Planning Analysis v) Open Space 5.47 Saved Policy L4 of the Medway Local Plan 2003 requires provision of open space in new residential developments and that where there is a proven deficiency, residential development proposals shall make open space provision in accordance with the following criteria considered relevant: i) Residential development likely to be occupied by 100 people or more shall include well located local open space for formal recreation on-site at a standard equivalent to 1.7 hectares per 1,000 population and open space for children s play and casual recreation on-site at a standard equivalent to 0.7 hectares per 1,000 population. Provision of some or all of the formal open space off-site or the improvement or extension of an existing off-site facility will be permitted where the Council is satisfied that this would be a better alternative; ii) Residential developments likely to be occupied by between 50 and 100 people should include well located open space for children s play and casual recreation on-site at a standard equivalent to 0.7 hectares per 1,000 population The quantum of open space proposed, which amounts to some 2.2ha of open space and landscape planting within the site (including Local Area of Play) would exceed the above criteria and the development would therefore also be consistent with Saved Policy L4 as a result. In the case of this Outline planning application, where the final number and type of dwellings is unknown, the requirement for the provision of open space will be reserved through a legal agreement to be resolved when a detailed Reserved Matters application is made In addition to the overall provision of open space within the Site, the proposals include the provision of pedestrian connectivity to the existing surrounding public footpath network (GB5) which runs to the north-east of the Site. In addition, there is an opportunity for a potential future pedestrian link from the Site into Bloors Lane Community Woodland to the north-western Site boundary. vi) Transport and Traffic 5.50 An assessment of the current conditions in the vicinity of the Site in terms of existing transport infrastructure, highway network and public transport provision, as well as pedestrian and cycling access has been undertaken as part of the accompanying Transport Assessment TA (i- Transport, October 2017) /A5/JM/ja 43 October 2017

49 Planning Analysis 5.51 Detailed discussions have been held with Medway Council Highways (as the Local Highway Authority) and Highways England (in respect of the Strategic Road Network) prior to the submission of the planning application. The scope of the accompanying Transport Assessment has been agreed with both parties Vehicular access into the Site will be formed via a simple priority T junction on Berengrave Lane approximately 25m south of the existing Site access. This new vehicular access will serve all 121 dwellings. The proposed new access is fully detailed on Proposed Site Access Arrangement (i-transport drawing ITB12519-GA-001 Revision B) and has been agreed in principle with Medway Council as part of the pre-application scoping process Junction visibility has been provided in accordance with the requirements set out in the Manual for Streets. The existing 30mph speed limit on Berengrave Lane requires minimum visibility splays of 2.4m x 43m to both the left and right for vehicles emerging from the Site onto the wider highway network. The submitted plan demonstrates these splays are achievable within the public highway In addition to the proposed new access, the existing site access will be retained to solely serve the existing bungalow, associated storage buildings and telecommunications mast. The existing access will not be used in connection with the proposed new residential development Internally, the Site will comprise of a main route through the Site and will connect to a series of minor/secondary internal roads. Due to the Outline nature of the planning application, the provision of precise car and cycle parking and refuse collection arrangements are not for determination at this stage, however, overarching principles are contained in the submitted Transport Assessment which demonstrate that such matters can be adequately addressed within the Site The proposed development is designed to allow easy pedestrian movement throughout the Site and connect with the existing surrounding Public Footpath network to form wider pedestrian and cycle routes within the Site and permeability to the wider area As part of the site access works, it is proposed to provide an uncontrolled pedestrian crossing on Berengrave Lane in the vicinity of the new site access (as shown on Proposed Site Access Arrangement, drawing ITB12519-GA-001 Revision B). This will improve pedestrian linkages from the proposed development towards Rainham town centre and Rainham railway station /A5/JM/ja 44 October 2017

50 Planning Analysis 5.58 The Site is located in a sustainable location and offers good opportunities for journeys to key local facilities and services undertaken by walking, cycling and public transport in accordance with national and local policy. These opportunities will be enhanced and facilitated by the provision of a sustainable transport strategy, including a travel plan, to ensure that future residents have the opportunity to travel to a range of everyday destinations by a choice of travel modes, thus minimising the impact of vehicular traffic on the local highway network In summary, the accompanying Transport Assessment demonstrates that the local network can accommodate the residual traffic generated by the development proposal during the peak hour periods without resulting in a severe increase in queuing and delay and is therefore in accordance with the policies set out in the NPPF. The submitted technical information also demonstrates that adequate vehicular and pedestrian access, parking and refuse collection arrangements will be provided. The proposed development would therefore accord with the NPPF and Saved Policies T1, T2, T3, T4, T11, T12, T13, T14 of the Medway Local Plan vii) Flooding and Drainage 5.60 The whole Site is located within Flood Zone 1 with less than 1 in 1,000 probability of fluvial or tidal flooding in any year. All forms of development are acceptable in Flood Zone 1 and the NPPF and NPPG identifies that the overall aim of the Sequential Test is to steer new development to Flood Zone 1. As the residential development would be situated in Flood Zone 1, the requirements of the Sequential Test are satisfied. Notwithstanding this and in accordance with the NPPF, a site-specific FRA is however still required due to the Site area being larger than 1 hectare The application is accompanied by a Flood Risk Assessment (Weetwood Services, October 2017) and a Foul and Surface Water Drainage Assessment (Weetwood Services, October 2017) The FRA and Foul and Surface Water Drainage Assessment considers the risk of flooding from other sources such as flooding from the sea and estuaries (tidal), rivers (fluvial), groundwater, reservoirs, surface water and sewage infrastructure. It also takes into account the effects of climate change On the basis of the above, the scheme accords fully with the requirements of the NPPF, and with Saved Policy CF12 and CF /A5/JM/ja 45 October 2017

51 Planning Analysis viii) Landscape and Visual 5.64 A Landscape and Visual Appraisal (EDP, October 2017) is submitted to accompany the application. The objectives of the LVIA are to assess the landscape character of the Site and its surroundings and to consider the landscape and visual qualities of the Site, its function in the landscape and its contribution to the wider landscape. The LVIA has been used to inform the design of the development and to explain the likely landscape and visual effects that may arise from it The Site does not fall within, or contain, any statutory landscape designations, and no such designations fall within 2km of the Site. However, the Site does fall within the locally designated Gillingham Riverside Area of Local Landscape Importance (ALLI). The main on-site consideration, in terms of ecology and landscape fabric, is noted as the areas of dense deciduous broadleaf trees that have been identified as a Priority Habitat Deciduous Woodland The Appraisal identifies the baseline conditions of the Site as having a generally low landscape value which is raised slightly to low-moderate, due to its ecological amenity. The Site context, as informed by the Zone of Primary Visibility, comprises the predominantly residential urban fabric along Berengrave Lane, in north Rainham. This development, whilst not unattractive, does little to contribute to the sense of place within the Lower Rainham Farmland Landscape Character Area (LCA) and it is assessed as having a low landscape value The Site comprises a commercial, and former commercial and now overgrown, land use that is at odds with, and visually and physically divorced from, the wider, generally agricultural, landscape, albeit with urban fringe and industrial influences, of the Lower Rainham Farmland LCA, in which it sits. In addition, the Site is surrounded by late C20th residential development that contributes little to its sense of place. For these reasons, the Appraisal notes the Site s contribution to the aims of the ALLI is also considered to be minimal and this designation is not considered to elevate the value of the Site Moreover, the assessment of the baseline value is consistent with that stated by Medway Council s Planning Officer (within the pre-application advice at Appendix C) which states: This Site although within the larger Rainham Farmland character area is within an area of low value due to recent developments adjacent to it and could be seen to be of low value as a result. Therefore, a development that is of high quality would help to enhance this area and rectify these issues /A5/JM/ja 46 October 2017

52 Planning Analysis 5.69 The Appraisal identifies visual receptors that may be able to obtain views of the Site, their distribution, character and sensitivity to change. It notes that the Site is visually very contained with very limited opportunity for visual interconnectivity, with visibility into the application Site primarily limited to: Users of Berengrave Lane - adjacent to the Site and for some 50m beyond its boundaries; Train users notably where the line is raised on an embankment, adjacent to the Site and for a limited distance beyond; Users of the two PROWs where they cross and run adjacent to the Site boundary; Facing residential properties on Berengrave Lane including those set back beyond the road, and the bungalow adjacent to the north-eastern Site boundary; and Community woodland there is also potential for glimpsed, filtered views, over intervening vegetation from the community woodland to the north-west, and from residential properties, and the cricket ground, immediately south of the railway line The landscape, visual and ecological sensitivities of the Site have influenced the proposed masterplan through an iterative process. Thus, the scheme proposals incorporate a degree of integral mitigation designed to avoid or reduce the potential landscape, visual and ecological effects. These measures can be seen on the Illustrative Site Layout Plan (drawing ) and Plan EDP 7: Landscape and Ecology Strategy (drawing EDP3943/08) as contained within the accompanying Appraisal report, and can be summarised as follows: Retention of key areas of deciduous woodland and scrub; Retention of the hedge along the north-western Site boundary, and its extension with new native hedge planting to the north; Retention of a green buffer to the bungalow and buildings adjacent to the north-eastern Site boundary; An informal, sinuous, development edge incorporating existing vegetation and species enriched grassland, SUDS features, areas of informal open space and recreational routes; A more formal layout, with street planting, within the development to reinforce the proposed street hierarchy and reflect the character of the local area; Enhancements to the PROWs that cross the Site; and Mitigation measures set out in the accompanying ecological reports /A5/JM/ja 47 October 2017

53 Planning Analysis 5.71 Whilst it is recognised that areas of woodland and scrub, as well as some trees beyond these areas, will be lost as a result of the development of the Site, trees which contribute to the wider landscape character, and are identified as the most important within the ecological and Arboricultural assessments, will be retained The Appraisal considers the effects on visual amenity arising from the proposed development. An assessment of the effects at each viewpoint receptor has been undertaken, with a summary of the results contained in Table 6.3 of the accompanying assessment. Largely the assessed levels of effect are classified as imperceptible, very low, low or minor/negligible, with only moderate effects highlighted for residential properties that immediately surrounding the Site (notably properties in Berengrave Lane, Holmoaks and Pembury Way) owing to their existing views of the Site. The Appraisal notes that this moderate level of effect is due primarily, to the sensitivity of receptors here rather than to the magnitude of change. It is also noted that the proposals would not be incongruous in this residential setting and that the magnitude of change experienced by residents would be mitigated, to some degree, by retention, management and enhancement of vegetation along the Site frontage and the set-back of the development beyond this boundary to reflect the development from along this road In conclusion, the accompanying Appraisal considers that the Site sites within the settlement at the norther edge of Rainham with the gently rising landscape south of the estuary. The location of the Site and its existing characteristics means that it is visually very well contained and already characterised by the urban environment. In essence, in landscape and visual terms, it is logical and easily assimilated addition to the existing settlement The proposals have been located and designed to minimise the effects on characteristic landscape fabric, landscape character, and visual amenity, and are considered to fulfil the requirements of the relevant saved policies of the Medway Local Plan Accordingly, the accompanying Landscape and Visual Appraisal concludes that the Site has landscape and visual capacity for the development as proposed on the masterplan, and that there is no in principle or policy landscape or visual reason why the Site should not be developed. ix) Ecology 5.76 The Site does not lie within any statutory or non-statutory designations, however the Medway Estuary and Marshes SPA, SSSI and Ramsar Site are located approximately 0.7km north east of the Site /A5/JM/ja 48 October 2017

54 Planning Analysis 5.77 A Preliminary Ecological Appraisal (The Ecology Partnership, April 2017) is submitted in support of the planning application. This Preliminary Ecological Appraisal, including an extended Phase 1 habitat survey was undertaken on 5 th April The Site was surveyed on foot and the existing habitats, land uses, dominant plant species in each habitat and any evidence of protected species recorded The majority of the habitats on Site are common and widespread throughout the local area and the UK as a whole. The Site is dominated by Deciduous Woodland Priority Habitat, which although is made up of semi-mature specimens is still considered to have ecological value. These areas of the woodland will be retained and enhanced as part of the proposed development The existing buildings on Site are considered to have negligible potential for roosting bat species. Demolition of the buildings is not considered to be under any constraints from roosting bat species and no further surveys are recommended. The Site is considered to have moderate quality for commuting and foraging bat species A Bat Activity Survey report accompanies the application. It details that dusk activity surveys were undertaken at the Site on 3 rd July, 8 th August and 4 th September In addition, two Anabats were deployed at the Site over an initial period of 7 nights (3 rd 9 th July 2017), a subsequent period of 6 nights (8 th 13 th August 2017) and lastly a further period of 6 nights (4 th 9 th September 2017) The three nights of dusk activity surveys and 19 nights of automated call recording with Anabats recorded 5 species of bat. Common and soprano pipistrelle were recorded almost nightly and foraged over the Site. These species were the most dominant across the Site. Noctule was frequent, but probably only commuting across the Site to other foraging areas. Serotine observations suggest occasional foraging. An unidentified Myotis bat was also recorded too infrequently to infer any pattern of activity Bat foraging was recorded both over the Site and the adjacent Community Woodland. Deciduous woodland is valuable habitat for a number of bat species and the local scale of 4km is a scarce resource. The Site is therefore likely to be of some value for local populations and common and soprano pipistrelle and serotine, assuming to be roosting off the Site as the Site s Preliminary Ecological Assessment identified little roosting potential within the red line boundary /A5/JM/ja 49 October 2017

55 Planning Analysis 5.83 To avoid impacts on the local bat population, as much woodland as possible should be retained around the development s edges. Enhancements are proposed for the retained woodland areas which can compensate for the decline in the total area of woodland. In summary, the Bat Survey Report concludes that the development would not impact upon the favourable conservation status of bats in the local area if significant features are to the retained and enhances, especially along the edges of the Site A field survey of the Site for reptiles was carried out between 8 June and 5 July Prior to the commencement of the survey, the Site was set up with artificial refugia for reptiles on 1 June A good population of two species of reptile were identified on site: slow worm and common lizard. These species occur in c1.1ha of tall grassland and open scrub in the north of the Site and lower numbers may occur elsewhere on the Site in smaller patches of suitable habitat that were not included within the survey. Mitigation, in the form of translocation of slow worms and common lizards are proposed as part of the scheme A field survey of the Site for breeding birds was conducted on three mornings between late May and mid-june The survey recorded a total of 37 bird species, of which 25 displayed evidence of at least possibly breeding. The most notable species was turtle dove, a species classified as globally vulnerable and UK Red List. One pair probably nested on the border with the Site and the community woodland. Five other common and widespread species of UK conservation interest (Red or Amber List), due to declines in their breeding population, at least possibly bred on the site: song thrush, starling, house sparrow, dunnock and bullfinch. Suitable habitat creation is proposed within the c1ha of retained vegetation to improve the site for turtle dove and minimise impacts on other Amber List species A Dormouse Survey report accompanies the application. Surveys were undertaken in June, July and August 2017 and did not find any evidence of dormice using any of the nest tubes within the Site. In September and October 2017 no evidence of dormice was identified, but wood mice were found to be using several tubes The Preliminary Ecological Appraisal identified that an active badger sett was found within the Site. Other evidence of badgers using the Site included the presence of latrines, snuffle holes and mammal pathways which were found to be present in various locations around the Site. A badger update survey letter (dated 19 th October 2017) accompanies the application, following further on-site survey work undertaken in early October It recommends that ground works be avoided within 15m of the sett, ensuring that the development would not result in the disturbance to the badgers or the integrity of the sett. On the basis of this exclusion zone, which is exceeded within the submitted Land Use Parameter Plan (drawing ), a licence from Natural England will not be required in respect of badgers /A5/JM/ja 50 October 2017

56 Planning Analysis 5.88 The submitted ecological information details that the Site is not considered likely to support GCNs, white-clawed crayfish, water voles or otters and no further surveys for these species are recommended In terms of ecological enhancement measures, these are included with the proposed development to help reduce potential ecological impacts. Specifically, areas of the woodland within the Site are being retained to maintain habitat and ecological connectivity and green corridors around the Site. Additional tree planting is shown to be carried out along the boundaries of the Site to enhance green corridors and provide additional habitat in line with local policy. The proposals also include the incorporation of log piles and bird nest boxes throughout the proposed development In summary, the proposals fully accord with the requirements of the NPPF and with Saved Policies BNE39, EC13 and EC14 of the Medway Local Plan x) Arboriculture 5.91 The Site does not lie within a Conservation Area and no trees within the Site are subject to a Tree Preservation Order (at present) An Arboricultural Development Report (tree:fabrik, September 2017) is submitted in support of the application. The report presents an analysis of the potential impact of the proposal on existing trees within the Site. A tree survey was carried out by tree:fabric in June 2017 in accordance with the guidance and recommendations of British Standards 5837, government guidance and current good practice A total of 85 individual trees and 28 groups were assessed within the Site. Of these: No trees or groups of trees were assessed as high quality (Category A); 29no. trees or groups of trees are of moderate quality (Category B); 81no. trees or groups of trees are of low quality (Category C); and 3no. trees or groups of trees are of such condition that they cannot realistically be retained as living trees in the context of the current land use for longer than 10 years (Category U) /A5/JM/ja 51 October 2017

57 Planning Analysis 5.94 In general, the tree stock within the Site is of varying health and condition formed principally of individual trees and dense scrub thickets. Species include Alder, Ash, Blackthorn, Cherry, Cypress, English Oak, Sessile Oak, Turkey Oak, Hawthorn, Horse Chestnut, Sycamore, Tree of Heaven, Walnut, Willow and various ornamental fruit and nut trees The proposed scheme has given careful consideration in order to minimise the potential negative impacts of development on retained trees through design and integration of the soft landscaping. Proposed buildings are located outside of the RPA of adjacent trees and set a distance from the tree crowns. As such, retained trees would not impact on the amenities of future occupiers or result in additional pressure from residents for inappropriate pruning or removal Whilst tree loss will inevitably occur in order to directly facilitate development, the majority of tree loss is formed by dense thickets of scrub and nursery stock that has established following a lapse in maintenance of the former Nursery grounds. This strategic loss maintains a strong sylvan framework and retains the appearance of the local and wider landscape To the west of the Site, the impact of a swale on Turkey Oak (T74) could be minimised through an appropriate future design. The form of the proposed swale could reasonably be engineered to minimise excavation within the RPA of the tree and would not therefore have an adverse impact on the trees future health or stability A comprehensive landscape strategy for the Site has been presented as part of the proposal and will provide significant new tree planting across the site. This will enhance the distribution of tree cover throughout the Site and provides a clear framework which can be applied within any subsequent Reserved Matters application Overall, given the existing low Arboricultural value of the Site and that no prominent features are proposed to be impacted, the proposed development is acceptable in Arboricultural terms and therefore accords with the NPPF and Saved Policies EC22 & EC23 of the Medway Local Plan xi) Agricultural Land Classification The agricultural land grading of the Site has been assessed (Agricultural Land Classification Report, RSK ADAS Ltd) using the system outlined in the Ministry of Agriculture, Fisheries and Food (MAFF, now Defra) publication Agricultural Land Classification of England and Wales Revised guidelines and criteria for grading the quality of agricultural land (October 1988) /A5/JM/ja 52 October 2017

58 Planning Analysis Provisional Agricultural Land Classification (ALC) maps, produced in the 1970s, classified the site as Grade 1 land. However, the provisional mapping exercise was not meant to give a detailed grading of small parcels of land and so the Site has been classified again, using the current ALC guidelines Fieldwork undertaken on the Site recorded soils which had mainly medium textured topsoils over similar or heavy textured subsoils and land quality was limited by texture and wetness limitations to Grades 2 and Subgrade 3a. Droughtiness was also identified as a limitation to land use on the higher ground The accompanying report identifies that the Site is currently unused for agriculture and most of the Site would require significant remediation prior to bringing it back into production, due to the size and age of the trees which are growing in blocks across the Site. Areas of scrub have been classified as agricultural but the main blocks of taller trees have been classified as farm woodland In conclusion, the accompanying report demonstrates that the Site would require significant remediation to bring it back into viable agricultural production, and therefore the Site is not classified as being best and most versatile agricultural land. In the context of NPPF para. 112 it is demonstrated that the use of this Site would utilise poorer quality [agricultural] land in preference to that of higher quality land. In addition, the Council recognises within the Development Options: Regulation 18 Consultation Report that to meet the required housing needs, full consideration will need to be given to all options for meeting development needs, including the development of greenfield sites in suburban/rural areas. The proposals therefore comply with the objectives of para. 112 of the NPPF and Saved Policy BNE48 of the Medway Local Plan in respect of agricultural land. xii) Archaeology An Archaeological Desk Based Assessment (Thames Valley Archaeological Services, August 2017) is submitted in support of the planning application. It identifies that the Site contains no known heritage assets, but a collection of prehistoric struck flint has been recovered during fieldwork in advance of a mast installation on the Site s south-eastern boundary The report identifies that the Site has not, until relatively recently, been developed when a number of relatively small buildings including sheds, outhouses and greenhouses were erected in its southern section associated with the Nursery. The construction of these structures, however, would not have led to major ground disturbance. The larger, northern part of the Site is covered in dense vegetation and appears not to have suffered any ground disturbance /A5/JM/ja 53 October 2017

59 Planning Analysis Should further archaeological mitigation measures be required, this can be secured by an appropriately worded Condition. It has, however, been demonstrated that the proposals comply with the objectives of NPPF para xiii) Noise An Environmental Noise Impact Assessment (Sound Advice Acoustics Ltd, October 2017) is submitted in support of the proposed development which considers both noise and vibration at the Site. The methodology for the noise impact assessment has been agreed with the Council s Environmental Protection Team Vibration surveys were undertaken at the Site between 21 st 25 th May 2017, with the main source of transient vibration within the Site being trains from the adjoining mainline railway line. The accompanying results demonstrate that no detrimental or structural vibration levels have been measured and therefore the probability of neighbouring building damage is low Ambient noise levels were recorded at the Site during May 2017 (between 20 th 25 th May), with assessments made in accordance with the relevant standards. Internal criteria have been set and calculations made in order to determine the minimum construction details required in order to meet the desired level within the proposed residential dwellings to satisfy noise policy The report details that with appropriate mitigation, including specified window glazing and ventilation, internal noise levels are acceptable in terms of the assessment to British Standard 8233: The proposed development will therefore ensure a satisfactory acoustic environment for the future occupants, in line with the objectives of the NPPF, the Noise Policy Statement for England and Saved Policy BNE3 of the Medway Local Plan xiv) Air Quality Whilst the Site is not located in an Air Quality Management Area (AQMA), the application is supported by an Air Quality Assessment (Phlorum Limited, October 2017) which has been carried out to assess both construction and operational impacts of the proposed development. The scope of the submitted Air Quality Assessment has been agreed with the Council s Environmental Protection Team in September /A5/JM/ja 54 October 2017

60 Planning Analysis The construction phase of the proposed development will involve a number of activities that could produce polluting emissions to air, predominantly these will relate to dust emissions. The accompanying report considers in detail dust emission magnitude for demolition, earthworks, construction and track-out associated with the proposed development. Before mitigation, the development is identified as having medium risk for nuisance dust soiling effects, low risk for PM10 health effects and low risk for ecology. By employing site specific mitigation, as set out in the accompanying report, it is demonstrated that the residual significance impact for the construction phase is negligible The report details air quality impacts associated with the operational phase of the development, taken at various receptors including residential properties and within the Rainham AQMA. A detailed dispersion model has been used to predict pollutant concentrations at existing receptors adjacent to roads where the greatest change in traffic flows are expected. It has been shown that a small increase in NO2 and PM10 concentrations are expected, however, overall the development is expected to have a negligible impact on air quality, including receptors within the Rainham AQMA In conclusion, the accompanying report demonstrates that the proposals comply with the objectives of para. 124 of the NPPF and Saved Policy BNE24 of the Medway Local Plan (2003). The development will not cause any unacceptable effects on health, amenity or the natural environment of the surrounding area. xv) Contamination A Phase 1 Geo-Environmental Desk Study Report (BRD Environmental Limited, June 2017) has been carried out in support of the application. The investigation comprises a desk study of geotechnical and geo-environmental factors pertaining to the Site, including a review of available historic maps and an examination of other available sources of geo-environmental information. A preliminary risk assessment is also contained within the Phase 1 Desk Study Report The proposed development complies with the objectives of NPPF para. 120 and Saved Local Plan Policy BNE /A5/JM/ja 55 October 2017

61 Planning Analysis xvi) Section 106 Heads of Terms It is anticipated that the Section 106 Agreement may comprise contributions or agreements towards: Affordable Housing; Education; Local Health Facilities; and Birds Disturbance Mitigation; The actual sums, triggers and precise wording is to be agreed throughout the application process, but all contributions must be substantiated and justified in the context of the NPPF and Regulations 122 and 123 of the Community Infrastructure Levy Regulations /A5/JM/ja 56 October 2017

62 Planning Balance/Conclusions 6.0 PLANNING BALANCE/CONCLUSIONS 6.1 Section 38(6) of the Planning and Compulsory Purchase Act 2004 states that the determination of planning applications must be made in accordance with the Development Plan unless material considerations indicate otherwise. 6.2 Firstly, the Development Plan is out-of-date, being that the Medway Local Plan for the plan period was adopted in 2003 (14 years ago). Whilst some policies have been Saved these are also out-of-date in light of the context of the NPPF. This position has been recognised by Medway Council within its pre-application advice (Appendix C). 6.3 Whilst Medway Council is in the process of preparing a new Local Plan this is still at a formative (Regulation 18) stage. As part of the Local Plan evidence base, the Council published a SLAA in January 2017 identifying potential sites for new residential development across its administrative area to meet its housing needs. Crucially, the Site Berengrave Nursery, Rainham (Site Reference: 817) was identified by the Council as part of the SLAA process as being suitable and available for residential development with an overall capacity of 151 units. This represents a clear direction of travel in respect of the potential for the Site to be developed for new housing, albeit on a more intensive basis (i.e. for a higher number of dwellings) than that proposed within this outline application. 6.4 Significantly, Medway Council has confirmed that it cannot demonstrate a 5-year housing land supply and therefore the relevant policies for the supply of housing should not be considered up-to-date (NPPF Para. 49). In this context, Policies BNE25 which relates to development in the countryside, and BNE34 which relates to the ALLI designation, both of which seek to restrict housing supply in Medway, must be considered out-of-date and should therefore only be afforded limited weight. 6.5 Given that policies for the supply of housing are out-of-date, para. 14 of the NPPF is engaged which provides for a presumption in favour of sustainable development, stating that permission should be granted unless any adverse effects of doing so would significantly and demonstrably outweigh the benefits when assessed against the policies in the NPPF as a whole. In the context of para. 14, this Statement demonstrates that there are no specific policies in the NPPF that indicate the development should be restricted (i.e. the Site does not fall within any of the specific designations listed in Footnote 9 of the NPPF) /A5/JM/ja 57 October 2017

63 Planning Balance/Conclusions 6.6 In terms of the sustainability of the proposed development, there would be clear economic gains from housing delivery, including affordable housing; in terms of the value of construction works; and in terms of the subsequent housing to the local economy. It has been demonstrated that the housing would be accessibly located, in close proximity to the urban centre of Rainham with its associated services and public transport facilities, reducing the need and dependence on private car travel. In addition, the proposals represent the redevelopment of PDL (in respect of the parts of the site associated with the retail use of the Nursery) which is aligned with the core principles of the NPPF. 6.7 In respect of the social dimension of the development, the proposals would provide much needed new homes, including affordable homes, assisting with the Council s persistent undersupply of a pipeline of 5 years housing land. There would also be clear social benefits associated with the supply of new affordable homes which fully meet the Council s policy requirements. Other important social benefits include the development of new open space within the Site; the inclusion of a children s play area; as well as the connectivity of the Site to the surrounding public footpath network which provides opportunities for both leisure/recreational pursuits, as well as accessibility to the urban centre of Rainham. 6.8 In respect of the overall landscape and visual impacts of the proposals, the accompanying Landscape and Visual Appraisal demonstrates that the location of the Site and its existing characteristics means that it is visually well contained and already characterised by the urban environment. Furthermore, the proposed development, in landscape and visual terms, is a logical and easily assimilated addition to the existing settlement of Rainham. Crucially, the overall landscape impact of the proposals must be balanced in the context of the reduced weight to be afforded to Policy BNE34 as a result of the engagement of NPPF para s 14 and 49, together with the clearly evidenced economic and social benefits of the scheme which have been demonstrated throughout this report. 6.9 The planning application is supported by a comprehensive suite of technical reports, which demonstrate that the proposed development does not give rise to residual adverse environmental impacts of a sufficient scale to indicate that development should be restricted and, where appropriate, Planning Conditions would be available to ensure that proposed mitigation measures are secured. Significantly, it has been demonstrated that the development of this Site is suitable, achievable, and available, and therefore deliverable in planning terms /A5/JM/ja 58 October 2017

64 Planning Balance/Conclusions 6.10 In conclusion, the proposals represent a residential-led proposal providing for a sustainable development including: Up to 121 dwellings (including up to 25% affordable housing); Creation of a new vehicular access from Berengrave Lane; Provision of 2.2 hectares of open space within the Site; Associated hard and soft landscaping and infrastructure within the Site; and Enhanced pedestrian linkages to the surrounding Public Footpaths and a potential pedestrian link to Bloors Lane Community Woodland (subject to further agreement with Medway Council) Following a thorough assessment of the proposals against planning policy guidance, it is concluded that the proposals represent an acceptable form of sustainable development that will deliver significant economic and social benefits and contribute to creating a high-quality environment. There are no adverse impacts of the development that would significantly and demonstrably outweigh these benefits, nor do policies suggest that development should be restricted (NPPF, Para. 14) As such, the proposals should be supported and planning permission granted without unnecessary delay, in accordance with agreed timescales set out within the Planning Performance Agreement /A5/JM/ja 59 October 2017

65 APPENDIX A: SITE LOCATION PLAN (DRAWING )

66

67 APPENDIX B: MC SCREENING OPINION (MC/17/3223) (3 OCTOBER 2017)

68 Decision Notice MC/17/3223 Elizabeth Davies BARTON WILMORE 7 SOHO SQUARE LONDON W1D 3QB Applicant's Name GLEESON STRATEGIC LAND Planning Service Physical & Cultural Regeneration Regeneration, Culture, Environment & Transformation Civic Headquarters Gun Wharf Dock Road Chatham Kent ME4 4TR Telephone: Facsimile: planning.representations@medway.gov.uk TOWN & COUNTRY PLANNING ACT 1990 Town & Country Planning (Environmental Impact Assessment) Regulations Location: BERENGRAVE NURSERY, BERENGRAVE LANE, RAINHAM, GILLINGHAM, ME8 7NL Proposal: Town and Country Planning Act (Environmental Impact Assessment) Regulations request for a screening opinion for an outline application for the construction of up to 140 residential dwellings with associated infrastructure, groundworks, demolition, open space and landscaping with all matters reserved except for access Take Notice that the Medway Council in pursuance of its powers under the above Act HAS DETERMINED THAT AN ENVIRONMENTAL IMPACT ASSESSMENT IS NOT NECESSARY for the development as described above in accordance with your request for a Screening Opinion dated 12 September, For the following reasons: 1 The proposed development has been assessed against the criteria in Schedule 2 to the Town and Country Planning (Environmental Impact Assessment) Regulations It is considered that an EIA is not required as the proposed development is unlikely to result in significant impacts on the environment and the impacts that may arise can be identified and addressed by the submission of appropriate supporting documents. Your attention is drawn to the following informative(s):-

69 You are advised that any subsequent planning application submitted will need to be accompanied by the following detailed assessments: Design and Access Statement. Archaeology/Heritage Assessment. Transport Statement. Flood Risk and Drainage Assessment. Contamination Desktop Study. Air Quality Assessment including an Emissions Mitigation Strategy. Noise Impact Assessment. A landscape Visual Impact Assessment. Ecological scoping survey and any subsequent recommended specific species surveys and details of mitigation. Draft Construction Environmental Management Plan. Agricultural Land Classification Report. A detailed assessment of the potential impacts of the proposal on winter birds to inform an appropriate assessment should a contribution towards mitigation measures in relation to bird disturbance not be forthcoming. This planning decision takes account of the cover letter and Environmental Impact Assessment Screening Report Issue 02 dated September 2017 received on 13 September Signed David Harris Head of Planning Date of Notice 3 October, 2017

70 APPENDIX C: MEDWAY COUNCIL PRE-APPLICATION ADVICE LETTER (PRE/17/2112) (4 OCTOBER 2017)

71 Please ask for: Majid Harouni Our Ref: PRE/17/2112 Date: 4/10/ 2017 Mr Andrew Wilford Barton Willmore The Observatory Southfleet Road Ebbsfleet, Kent DA10 0DF Planning Service Physical & Cultural Regeneration Regeneration, Culture, Environment & Transformation Civic Headquarters Gun Wharf Dock Road Chatham Kent ME4 4TR Telephone: Facsimile: Minicom: Dear Mr Andrew Wilford TOWN AND COUNTRY PLANNING ACT 1990 Town and Country Planning (General Permitted Development) Order 2015 APPLICATION NUMBER: PRE/17/2112 LOCATION: Berengrave Nursery, Berengrave Lane, Rainham, Kent. PROPOSAL: Construction of between dwellings and associated vehicular access (as shown in the illustrative drawing for 121 dwellings). I refer to our meeting of 30/08/17 regarding the above and would provide the following information. The NPPF and Medway Local Plan 2003 are considered relevant in assessment of this proposal. Paragraphs 7, 8, 14 and 49 are relevant and 197 of the NPPF state that there should be presumption in favour of sustainable development and it is desirable that proposals development should be considered against an up to date development plan. Medway Local Plan (MLP) was adopted in 2003 and having regard to paragraph 215 of the NPPF due weight should be given to relevant policies BNE1, BNE25, BNE34, BNE44 and H3 of the Local Plan according to their degree of consistency with the NPPF. Medway Council has assessed the degree of consistency with the NPPF and a report to that effect was presented to the Planning Committee on 09/09/2014. This report can be access on the Council s Website.

72 Work has started on the production of a new Local Plan in 2014, with a planned adoption date of early The detailed programme for this work is outlined in the Council s Local Development Scheme, published in December Five Year Housing Supply The housing trajectory and the required delivery rate indicate that the Council currently does not have a five year housing land supply. As a result of the shortfall in the housing land supply, paragraphs 14 and 49 of the NPPF apply, and relevant policies for the supply of housing should be considered not up-to-date. The site does not fall within any designations outlined within footnote 9 of the NPPF. However, the urban boundaries as defined in the proposals map for the 2003 Medway Local Plan fall away and so does the weight carried by policy BNE25. As a result the sustainability of the site needs to be assessed in line with the definition of sustainable development as outlined in the NPPF. Principle of Development This site was assessed in the Strategic Land Availability Assessment (SLAA) ref The assessment raised concern about loss of high quality agricultural land. It deemed that this site is suitable for residential development. The proposal comprises a development of approximately 121 new residential dwellings. The site falls within the boundaries of three spatial policies within the Medway Local Plan These include: BNE25 and BNE34. These policies refer to development in the countryside and areas of local landscape importance. As noted policy BNE25 is given little weight as per paragraph 49 of the NPPF and so the sustainability of the site is to be assessed instead. Therefore the key considerations here are: sustainability of the development, the landscape impact, of the proposed housing mix, affordability, permeability and better pedestrian access link to the adjoining Community Woodland and public right of way to the north more direct access to the town centre and Rianham Railway Station via Childscroft Road and Tufton Road, highway improvement and landscape mitigations. Sustainability Paragraph 7 of the NPPF sets out the three dimensions to sustainable development, explaining the environmental, social and economic considerations that plan making and decision taking must address. Any assessment needs to encompass all of the dimensions of sustainable development and note that they are mutually dependent as per paragraph 8 of the NPPF. Economic The economic sustainability of the site has two parts: the sustainability of the site economically for residents and jobs growth created from the site. Significant weight can be attached to the benefits of delivering housing, including affordable housing, against the

73 identified need and given the emphasis for housing delivery in national policy. Housing delivery has economic benefits in terms of construction phase, employment and the expansion of the resident workforce. Economically the site is located close to the Rainham Town Centre that will provide job opportunities for residents. Also Rainham Railway Station is accessible to the site and can provide access to wider employment opportunities. Social The social part of sustainable development considers that a level of community facilities needed to be provided locally for a development. NPPF paragraph 7 states that the social role encompasses: creating a high quality built environment, with accessible local services that reflect the community s needs and support it health, social and cultural well-being. Rainham town centre is approximately 500m to the south east of the site and provides a range of services. The site is within short walking distance to Rainham Station and good public transport. It was agreed during our discussion that any layout design will seek to respond to the site s short coming by improving permeability by enhancing connection to the public highway and Community woodland. Environmental The impact on the environment is of vital importance to the sustainability of a site and this is assessed through paragraphs of the NPPF. As stated previously the site is not within any environmental designations as outlined in footnote 9 to paragraph 14 of the NPPF. In addition the site is grade 1 and 2 agricultural land. This is the best and versatile agricultural land. As such this area demands a certain level of protection from development as outlined in national planning policy (NPPF). NPPF paragraph 112 states: Local planning authorities should take into account the economic and other benefits of the best and most versatile agricultural land. Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality. Therefore your application needs to demonstrate and justify the loss of the land to housing development, as required by the NPPF. Land use history of the site might be helpful to establish the last farming activities on this site and land uses that might have detracted from the quality of the soil. Landscape The site falls within the area of Medway Local Plan saved policy BNE34. The policy seeks to protect landscape in its primary purpose rather than to restrict housing. The policy only permits development in two instances:

74 (i) it does not materially harm the landscape character and function of the area; or (ii) the economic and social benefits are so important that they outweigh the local priority to conserve the area s landscape. Development within an Area of Local Landscape importance should be sited, designed and landscaped to minimise harm to the area s landscape character and function. In reference to part i the harm to the landscape character need to be assessed. The Medway Landscape Character Assessment (2011) built upon the work of the policy justification for BNE34 and clarifies the value of landscape within Medway. It states that the site falls within the Lower Rainham Farmland and the guidelines indicate that further built development should be resisted. The landscape character area that the site falls within is Gillingham Riverside. The character of this area is described as: Rural landscape of orchards and fields with country lanes. While the function is threefold to provide a buffer between urban Medway and the significant environmental designations, allow access to the rural landscape and help the setting of Medway. This site although within the larger Rainham Farmland character area is within an area of low value due to recent developments adjacent to it and could be seen to be of low value as a result. Therefore a development that is of high quality would help to enhance this area and rectify these issues. Housing mix Paragraph 50 of the NPPF requires local planning authorities to plan for a mix of housing based on current and future demographic trends, market trends and the needs of different groups in the community and to identify the size, type, tenure and range of housing that is required in particular locations, reflecting local demand. The North Kent Strategic Housing Market Assessment (SHMA) (November 2015) stated that the council may seek to follow a similar size distribution in its market housing delivery as in the current total housing stock, based on the 2011 Census (approximately 10% one bed, 25% two bed, 49% three bed, 13% four bed and 3% at least five bed). In compliance with the Council s policy H3 at least 25% of the total number of the dwellings on this site should be affordable housing. The expected ration of 60% rented and 40% shared ownership. Also in addition to 1, 2 and 3 bedroom units, large (4bed units) also would be sought in this development. Please note that 5% of the affordable units should be disabled compliance. Highway I understand that your highway consultant has discussed highway issues relating to the development of this site with the Council highway Officer Michael Edward, as such I do not make comment on this issue. Surface water

75 As discussed during our meeting the issue of surface water management /Sustainable Urban Drainage system should be designed and mitigated as part of the design of the dwellings and the master planning of the site. Other issues Having regard to the previous uses of the site land contamination assessment should be carried out and where necessary mitigation measures proposed. Also archaeological and ecological potential of the site would need to be assessed. In addition a tree survey would need to be undertaken to assess the potential impact of the proposed development. The impact of the presence of railway line along the southern boundary of the site would need to be assed with regard to noise and vibration. It is important to note that residential development on this site would be expected to make developer contribution. I therefore draw your attention to the Council s Supplementary Planning Document called Guide to Developers Contribution this can be view on the Council s web site. Please also see the link provided blow with regard to contribution for the protection of birds in North Kent Marshes SPA/Ramsar Sites. sturbanceinnorthkent.aspx I hope you find the above helpful, if you have any further questions; you can contact me on the above contact details. This opinion is given on an informal base and is at officer s level only, without prejudice to any formal decision that may be made by the Local Planning Authority. Yours sincerely M. Harouni Planning Officer

76 APPENDIX D: ECONOMIC BENEFITS STATEMENT

77 BERENGRAVE NURSERY, RAINHAM Economic Benefits Statement SUBMITTED ON BEHALF OF GLEESON STRATEGIC LAND October 2017

78 BERENGRAVE NURSERY, RAINHAM ECONOMIC BENEFITS STATEMENT SUBMITTED ON BEHALF OF GLEESON STRATEGIC LAND October 2017 Project Reference: Status: Final Issue/Revision: 1 Date: 19/10/17 Prepared By: NL Checked By: SH/JM Authorised By: JM Barton Willmore LLP The Observatory Southfleet Road Ebbsfleet Dartford DA10 0DF Tel: Ref: 27239/A5 natalie.lillis@bartonwillmore.co.uk Date: October 2017 COPYRIGHT The contents of this document must not be copied or reproduced in whole or in part without the written consent of Barton Willmore LLP. All Barton Willmore stationery is produced using recycled or FSC paper and vegetable oil based inks

79 CONTENTS PAGE NO 1.0 INTRODUCTION PLANNING POLICY CONTEXT ECONOMIC BENEFITS OF THE PROPOSED DEVELOPMENT 09

80 Introduction 1.0 INTRODUCTION 1.1 This report has been prepared on behalf of Gleeson Strategic Land Ltd (the Applicant) in support of an Outline planning application submitted in respect of Berengrave Nursery, Berengrave Lane, Rainham. The proposed development will comprise: Outline Planning Application (with all matters reserved except for means of access) for demolition of existing structures and erection of up to 121 residential dwellings including new vehicle access, internal roads, car parking, open spaces, sustainable urban drainage systems, earthworks and associated landscaping and infrastructure. 1.2 In order to place the economic benefits in their context, the remainder of this report is structured as follows. 1.3 Section 2 of the report will briefly review the relevant planning policy at national and local levels, focusing on the economic growth aspirations within the area. 1.4 Section 3 of the report will assess the potential economic benefits resulting from the Proposed Development both during the construction and occupational phases. This will consider the following: Construction employment; Economic output (Gross Value Added) generated across the construction phase; Population generated by the proposed scheme; Economically active population generated; Commercial Expenditure per annum; New Homes Bonus generated; and Council Tax /A5 October 2017

81 Introduction 2.0 PLANNING POLICY CONTEXT NATIONAL ECONOMIC POLICIES i) National Planning Policy Framework (NPPF) (27 March 2012) 2.1 The NPPF is written in the context of achieving sustainable development within three dimensions being; economic, environmental, and social, as follows: sustainable development is about positive growth making economic, environmental and social progress for this and future generations Specifically in respect of its economic dimension, the NPPF promotes strong growth in achieving the overarching objective of sustainable development. In summary, the economic dimension of sustainable development is expected to provide the following: an economic role contributing to building a strong, responsive and competitive economy, by ensuring that sufficient land of the right type is available in the right places and at the right time to support growth and innovation; and by identifying and coordinating development requirements, including the provision of infrastructure In order to achieve sustainable development, the NPPF sets out 12 core planning principles which are intended to underpin both plan-making and decision-taking. The importance of residential and commercial development in achieving the wider economic growth aims of the NPPF is clear from these core planning principles. In this context plan-making and decisiontaking should: proactively drive and support sustainable economic development to deliver the homes, business and industrial units, infrastructure and thriving local places that the country needs In delivering sustainable development the NPPF confirms that the Government is committed to ensuring that the planning system does everything it can to support sustainable economic growth and that Planning should operate to encourage and not act as an i mpediment to 1 Page i, Ministerial Foreword, National Planning Policy Framework, 27 March Paragraph 7, page 2, National Planning Policy Framework, 27 March Paragraph 17, page 5, National Planning Policy Framework, 27 March /A5 October 2017

82 Introduction sustainable growth. Significant weight should therefore be placed on the need to support economic growth through the planning system. 2.5 The role of residential and commercial development in achieving wider economic growth is clearly emphasised in the NPPF, and it is considered that the proposed development fully complies with these objectives. The material weight in planning decisions of economic impact can be seen in the appeal (June 2016) discussed below. 2.6 In Land south of High Street, Milton-under-Wychwood, West Oxfordshire (PP/D3125/W/16/ ), in relation to the development of 62 dwellings the Inspector stated: The proposed development would have a positive effect on the local economy; about 60 direct and indirect construction jobs would be created, direct and indirect construction gross value added (GVA) to the economy would be about 8 million, an economically active development population of about 78 persons would generate GVA of about 3.7 million per annum, there would be a New Homes Bonus of 0.6 million, and the Council would receive about 115,800 per annum from the payment of Council Tax. There is no evidence to indicate that there would be any loss of local revenue resulting from the proposed development. Paragraph 7 of the NPPF states that there are three roles of sustainable development; economic, social and environmental. The effect of the proposed development on the local economy has already been considered and has been found to be positive. (Paragraphs 41 & 44). 2.7 This example highlights how housing can comply with the economic principles outlined in the NPPF and moreover the increased role housing plays in delivering these economic ambitions. ii) Housing and Planning Act Previously, Local Planning Authorities, under Section 70 of the Town and Country Planning Act as amended by section 143 of the Local Act 2011, should have regard to material considerations in dealing with planning applications, including any local finance consideration, including: a) A grant or other financial assistance that has been, or will or could be, provided to a relevant authority by a Minister of the Crown, or b) Sums that a relevant authority has received, or will or could receive, in payment of Community Infrastructure Levy /A5 October 2017

83 Introduction 2.9 There was, however, concern that despite amendments to the Planning Practice Guidance [Reference ID: 21b ], the potential financial benefits of development were not being fully explained. The Planning Practice Guidance clarifies local finance considerations may be noted within committee reports dealing with applications for housing (even where they are not material to the decision) The Housing and Planning Act received Royal Assent on the 12 th May It has the strategic objective of increasing newbuild output and improving affordability. Section 155 refers to local planning authorities: information about financial benefits, emphasising the need to clearly set out the financial benefits of development, stating: (1) A local planning authority in England must make arrangements to ensure that the required financial benefits information is included in each report which (a) is made by an officer or agent of the authority for the purposes of a non-delegated determination of an application for planning permission, and (b) contains a recommendation as to how the authority should determine the application in accordance with section 70(2). (2) The required financial benefits information is (a) (b) (c) a list of any financial benefits (whether or not material to the application) which are local finance considerations or benefits of a prescribed description, and which appear to the person making the report to be likely to be obtained (i) by the authority, or (ii) by a person of a prescribed description or (if regulations so provide) by any person, as a result of the proposed development (if it is carried out); in relation to each listed financial benefit, a statement of the opinion of the person making the report as to whether the benefit is material to the application; any other prescribed information about a listed financial benefit. iii) The Housing White Paper Fixing our Broken Housing Market (February 2017) 2.11 The Housing White Paper sets out a programme of reform to tackle the long-standing problems in the housing market and ensure that more homes are built in the right places. It has no legal standing but it does provide a basis for further consultation and discussion with interested or affected groups /A5 October 2017

84 Introduction 2.12 The Housing White Paper highlights that the underlying issue in the housing market is the undersupply of new houses. In the Introduction to the White Paper, it is noted that since the 1970s there has been an average of 160,000 new homes built each year in England. However, it is widely acknowledged that England requires 225,000 to 275,000 new homes each year in order to keep pace with population growth and to address the historic undersupply Paragraph 1.29 notes that policies in plans should allow a good mix of sites to come forward for development, so that there is choice for consumers, places can grow in ways that are sustainable, and there are opportunities for a diverse construction sector As part of a suite of options identified to make more land available for homes, the paper sets out its increasing enthusiasm to bring forward A new generation of new communities stating their aim to make the most of the potential for new settlements alongside developing existing areas. (para 1.35). The extent to which this and other aspirations in the White Paper are realised will depend upon the detail of the very many areas of further policy that the Government promises to consult on shortly. iv) Planning for the right homes in the right places: consultation proposals 2.15 The White Paper, Fixing our Broken Housing Market1 ( the housing White Paper ), set out proposals to tackle the housing challenge that our country faces, as a key part of building a stronger, fairer Britain where people who work hard are able to get on in life. It argued that we need to build more houses of the type people want to live in, in the places they want to live The consultation document, paragraph 24 states that t here is considerable economic evidence that demonstrates that growth in house prices (and therefore worsening affordability) is inversely related to the level of house building. This indicates that the proposed development is supporting the delivery of housing in the area, provided a choice of housing type whilst contributing to making housing more affordable. LOCAL ECONOMIC POLICY /A5 October 2017

85 Introduction v) Medway Local Plan Medway Council (MC) is in the process of preparing a new Local Plan ( ) which will replace the 2003 Medway Local Plan. The first stage Issues and Options consultation was held between January and February A second stage Development Options consultation was undertaken between January and May The Development Options consultation recognises that there is an OAN of 29,463 dwellings (1,281 dpa) for the plan period ( ) To support the preparation of the new Local Plan, MC has published a Strateg ic Land Availability Assessment (SLAA) in January 2017 focussing on the potential for residential development within its administrative area. A total of 53 sites were deemed to be suitable, available and achievable for residential development amounting to a potential for 5,980 new residential units across Medway. Site 817: Berengrave Nursery, Rainham is identified within the published MC 2017 SLAA as Suitable and Available for residential development with a capacity of 151 units The role of the Medway Local Plan is to plan positively for the development and infrastructure needed across the area. The objectives for the plan include to boost the performance of the local economy by supporting local businesses to grow and attracting inward investment through the provision of good quality employment land that meets the needs of businesses, and to secure and extend higher value employment opportunities. The Local Plan Issues and Options consultation regonises that as Medway s population grows and ages, there is a need to ensure the right mix of housing is available for local people. vi) Strategic Housing and Economic Needs Assessment (SHENA) (March 2015) 2.20 Medway Council and Gravesham Borough Council jointly commissioned a Strategic Housing and Economic Needs Assessment (SHENA) (2015) to identify development needs for housing, employment and retail land. It was prepared due to the degree of interdependence in housing and employment markets The SHENA refers to Medway s growing population, which increased by 9% (271,100 people) over the 12 year period from 2001 to It discusses the 2013 mid-year population estimates, highlighting the age specific changes over the period. It comments that there was a 28% increase in the 60+ age cohort over the period, the highest proportional change over the period. This reflects the ageing nature of the Medway population, which is a slightly more /A5 October 2017

86 Introduction pronounced trend than is evident in neighbouring Gravesham. The low 2% growth level in the 0 to 15 age cohort further emphasises the ageing nature of the population It is noted within the SHENA that the reduction in the 30 to 44 age cohorts has housing implications for the types of stock and size required, as well as economic implications for local working, the area s skills and occupation levels, and the ability to secure local economic growth (paragraph 2.18) /A5 October 2017

87 Economic Benefits 3.0 THE ECONOMIC BENEFIT OF THE PROPOSED DEVELOPMENT 3.1 This section has been prepared to assess the economic benefits that would arise from the grant of planning permission for the Proposed Development. The economic benefits assess the positive effects on economic activity within an area. This can be identifie d by a number of different indicators, including GVA (gross value added), job generation, wages and expenditure. The provision of these indicators resulting from the Proposed Development will indicate the potential increase in economic wellbeing of the loc al economy. 3.2 The Application will generate a number of key economic benefits as follows. i) Construction Phase 3.3 The benefits associated with the construction phase have been calculated using the Labour Forecasting Tool (LFT) which is able to produce labour forecasts based on historic data. The LFT has been developed by the Construction Industry Training Board (CITB) and is an industry standard. The tool focuses on forecasting labour demand on a month -by-month basis by each occupational group throughout the construction phase of the Proposed Development. 3.4 Using the LFT forecasts, construction of the Proposed Development would generate an average of 65 jobs per month over the period 2018/19 to 2021/22 construction phase. 3.5 Based on the LFT figures, the level of GVA per annum generated throughout the construction phase of the development can be anticipated. GVA is a measure of economic impact, distributed through retained profit and wages. Based on average GVA per construction worker of 46,500 per annum (Experian Economic), over the construction phase, GVA could generate around 9.5m. 3.6 The provision of 65 4 full time equivalent direct construction jobs will have a positive effect on industries within the construction supply chain, referred to as the indirect effect. To deduce the indirect employment effect a type 1 employment multiplier of has been applied to the direct jobs figure, resulting in an estimate that a further 39 6 indirect jobs will be supported 4 Figure Subject to Rounding 5 Scottish Government, Type I, employment multipliers, Scotland 2014 (SIC 2007 basis) 6 Figure Rounded /A5 October 2017

88 Economic Benefits during the construction period, generating a 5.9m in GVA. This equates to a total GVA over the construction period (per annuum) of some 15.4m. ii) Completed Development a) Future Residents and Economically Active Population 3.7 Based on an average household size per number of bedrooms, accounting for a mix of one to four-bedroom dwellings (average housesold sizes between 1.33 to 3.22, 2011 Census), the proposed development could accommodate 304 residents (assuming 121 dwellings). It is assumed, based on the existing proportion of economically active residents (the percentage of the entire population who are economically active 7 equating to 53%, Nomis, Labour Market Profile 2016), that the total scheme could accommodate 161 economically active residents, of which 152 would be assumed to be in employment (based on current employment profile, Nomis April 2016 March 2017) 8. b) Future Resident Gross Value Added Contribution 3.8 GVA data can be used to provide an estimate of a local area s contribution towards UK economic growth. New homes accommodate a growing workforce which will deliver economic output. Experian Economics provide data on total GVA output and workforce jobs at a District level. Utilising this data, it has been established that within Medway the GVA per worker is around 44,600 9 per annum. Based on 161 future residents assumed to be in employment the total scheme could generate around 6.8m in GVA per annum (based on current values). c) Commercial Expenditure 3.9 Experian provides up to date retail and leisure expenditure data for all local authorities across the UK. Experian report (Experian Retail Planner Data, 2015) that the average annual household expenditure on convenience (food), comparison (non -food), and leisure goods and services is as follows: Convenience - 5,183 per household per annum Comparison - 7,590 per household per annum 7 Economically active refers to people avalaible/seeking work. 8 Numbers subject to rounding 9 Oxford Economics, Average , subject to rounding /A5 October 2017

89 Economic Benefits Leisure - 6,398 per household per annum 3.10 On the basis of these figures, we calculate that the provision of up to 121 dwellings will generate an annual convenience goods expenditure of 0.6m; comparison goods expenditure of 0.9m; and expenditure on leisure goods and services of 0.8m. This represents an additional 2.3m of total commercial expenditure per annum which is available to be spent within the local area and beyond. d) New Homes Bonus 3.11 The New Homes Bonus Calculator provided by the Department for Communities and Local Government confirms that the provision of up to 121 new homes would equate to a New Homes Bonus of approximately 0.7m delivered over four years 10. e) Council Tax 3.12 Based on an average council tax 11 value within Medway, we calculate that the Proposed Development could generate approximately 0.2m in council tax payments per annum. Summary 3.13 Based on the evidence outlined in this report and summarised in the appended Info-graphic, it is estimated that construction period 2018/19 to 2021/22 the Proposed Development will contribute: Construction Phase Construction jobs generated monthly - 65 Indirect jobs generated monthly - 39 Direct Construction GVA - 9.5m Indirect GVA - 5.9m Completed Development/Operational Phase Resident population generated Based on the delivery of units across council Tax Bands D & E 11 Current 2017/2018 council tax values, based on Bands D & E /A5 October 2017

90 Economic Benefits Of which are economically active Of which are assumed to be in employment GVA generated per annum by resident population in employment - 6.8m Additional commercial expenditure per annum - 2.3m New Homes Bonus - 0.7m Council Tax per annum - 0.2m /A5 October 2017

91 APPENDIX E: MEDWAY COUNCIL SLAA ASSESSMENT (SITE 817: BERENGRAVE NURSERY)

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